IN SITU BURNING GUIDELINES FOR ALASKA · In Situ Burn Guidelines for Alaska Revision 1 – August 2008 2 Administrative Update: March 2018 Green Zone: Safe Air Quality. Predicted

IN SITU BURNING GUIDELINES FOR ALASKA

In Situ Burn Guidelines Advisory Note:

1. Revisions to these guidelines are developed by the Science and Technology Committee and approved

by the ARRT. The most current version of the guidelines is available on the ARRT website at:

http://dec.alaska.gov/spar/perp/plans/uc/Annex%20F%20(Jan%2010).pdf

2. In September 2009, the ARRT Co-Chairs requested, on behalf of the ARRT, assistance from the NRT

in updating the In-Situ Burning Guidelines for Alaska, including a reevaluation of recommended limits

for short term exposure to particulate matters.

http://dec.alaska.gov/spar/perp/plans/uc/Annex%20F%20(Jan%2010).pdf

(This page intentionally blank)

ALASKA DEPT OF ENVIRONMENTAL CONSERVATION

U.S. COAST GUARD SEVENTEENTH DISTRICT

U.S. EPA, REGION 10 ALASKA OPERATIONS OFFICE

In Situ Burning Guidelines for Alaska

Revision 1

August 2008

In Situ Burn Guidelines for Alaska Revision 1 – August 2008 ii Administrative Update: March 2018

(This Page Intentionally Blank)

In Situ Burn Guidelines for Alaska Revision 1 – August 2008 iii Administrative Update: March 2018

Table of Contents

Table of Contents ......................................................................................................................... i

Glossary and Acronyms .............................................................................................................. 1

How to Use In Situ Burning Guidelines for Alaska ...................................................................... 3

1. Introduction ........................................................................................................................... 5

Applicability ........................................................................................................................... 5

Background .......................................................................................................................... 5

Updates in this Revision ....................................................................................................... 6

2. Operational considerations ................................................................................................... 9

In Situ Burning in Relation to Mechanical Recovery ............................................................. 9

Optimal Conditions for Burning ............................................................................................ 9

Oil Thickness and Containment ........................................................................................... 9

Emulsification ..................................................................................................................... 11

Weathering ......................................................................................................................... 11

Waves ................................................................................................................................. 12

Burn Volumes ..................................................................................................................... 12

Residues ............................................................................................................................ 12

Monitoring, Sampling, and Trial Burns ............................................................................... 14

Safety of Personnel. ........................................................................................................... 14

Wildlife ................................................................................................................................ 15

3. Safe Distance ..................................................................................................................... 17

The Public Safety Criterion ................................................................................................. 18

Safe Distance in Populated, Flat Terrain ............................................................................ 19

Authorization in Cook Inlet and on the North Slope ........................................................... 29

PM2.5 National Ambient Air Quality Standard ...................................................................... 29

Consideration of Moving Source ........................................................................................ 30

Conditions of Authorization ................................................................................................. 31

Notification System ............................................................................................................. 31

Notification Levels............................................................................................................... 31

Post-Authorization Requirements ....................................................................................... 32

4. Public Health and the Environment .................................................................................... 33

Public Health Considerations.............................................................................................. 33

Environmental Considerations ............................................................................................ 38

5. References ......................................................................................................................... 45

In Situ Burn Guidelines for Alaska Revision 1 – August 2008 iv Administrative Update: March 2018

Appendices:

Appendix 1: Application and Burn Plan .................................................................................... 49

Appendix 2: FOSC/SOSC Review Checklist In Situ Burning Guidelines for Alaska ................ 53

Appendix 3: Sample Unified Command Decision Document for In Situ Burning .................... 59

Appendix 4: Class I Areas in Alaska ........................................................................................ 61

Appendix 5: Air Quality Monitoring Equipment in Alaska .......................................................... 63

Appendix 6: Fire Danger Rating for Inland Areas ................................................................... 65

Tables and Figures:

Table 1 Optimal Conditions for Effective Burning of Alaska North Slope Crude Oil ................ 10

Table 2 Residue Produced During the Newfoundland Offshore Burn Experiment ................... 13

Table 3 Characterization of Residues from Laboratory Test Burns of Alaska

North Slope Crude .................................................................................................... 13

Table 4 Safe Distances Between In Situ Burns and Downwind Populated Areas

in Flat Terrain ............................................................................................................ 19

Table 5 ALOFT-FT Predictions of Downwind Safe Distances for Ground-Level PM2.5

Concentrations of 65 Micrograms per Cubic Meter over Flat Terrain. ...................... 30

Table 6 Air Quality Standards. .................................................................................................. 34

Table 7 Air Quality Index Values and Associated Health Effects. ............................................. 35

Figure 1: Zones for In Situ Burns on Populated Flat Land, and on Water

Within 3 Miles of Shore ............................................................................................. 21

Figure 2. Example of Zones for an In Situ Burn Over Land or on Water

Within 3 Miles of Shore ............................................................................................. 23

Figure 3: Zones for In Situ Burns on Water more than 3 Miles from Shore ............................ 25

Figure 4. Example of Zones for an In Situ Burn on Water at least 3 miles from Shore............ 27

Figure 5. In Situ Burn Zones .................................................................................................... 57

In Situ Burn Guidelines for Alaska Revision 1 – August 2008 1 Administrative Update: March 2018

Glossary and Acronyms

AAC: Alaska Administrative Code.

ADEC: Alaska Department of Environmental Conservation, also referred to as “DEC”

ALOFT-FT: A Large Outdoor Fire plume Trajectory-Flat Terrain

ARRT: Alaska Regional Response Team.

ASTM: American Society for Testing and Materials.

BBL: Barrel of oil.

Burning Agents: Those additives that, through physical or chemical means, improve the

combustibility of the materials to which they are applied

CFR: Code of Federal Regulations.

Controlled burn:Combustion that is started and stopped by human intervention.

Complex terrain: Land that rises more than 10 percent of the atmospheric mixing layer height,

which is where the smoke plume becomes level, as predicted by the National Weather

Service or reported by smoke observers.

DOC: U.S. Department of Commerce.

DOI: U.S. Department of the Interior.

DOI-FWS: U.S. Department of the Interior-Fish and Wildlife Service

DOI-NPS: U.S. Department of the Interior-National Park Service

EPA: U.S. Environmental Protection Agency.

ESA: Endangered Species Act

Flat terrain: Waterbodies and land that rises less than 10 percent of the mixing layer height which

is where the smoke plume becomes level, as predicted by the National Weather Service or

reported by smoke observers.

FOSC: Federal On-Scene Coordinator.

IC: Incident Commander

ICS: Incident Command System

In Situ Burn Guidelines for Alaska Revision 1 – August 2008 2 Administrative Update: March 2018

Green Zone: Safe Air Quality. Predicted concentrations of particulates will not exceed established

air quality standards.

In situ burning: Combustion of oil on the surface where it spilled. “In situ” is Latin for “in place.”

Excludes well-control, waste disposal, burning of oily vegetation, and adding a burning

agent.

MOA: Memorandum of Agreement

NAAQS: National Ambient Air Quality Standard

NCP: National Oil and Hazardous Substances Pollution Contingency Plan

NOAA: National Oceanic and Atmospheric Administration.

NRT: National Response Team.

PAH: Polynuclear Aromatic Hydrocarbon.

PM2.5: Particulate matter with diameter of 2.5 microns or less.

PM10: Particulate matter with diameter of 10 microns or less.

Populated Area: One or more persons physically present who are not spill responders under the

control of the Unified Command and a spill-specific worker safety plan.

Red Zone: Unsafe Air Quality. Predicted concentrates of particulates will exceed established air

quality standards.

Safe distance: Downwind from a fire, the greatest radius at which PM2.5 emissions near ground

level diminish to 1-hour concentrations equal to their National Ambient Air Quality Standard

concentrations averaged for 24 hours or less.

Site safety plan: Incident-specific document for response worker protection that addresses the in

situ burning operation, follows 29 CFR 1910.120 OSHA regulations, and is signed by the

responsible party or the response action contractor. May also follow the National Response

Team Science and Technology Committee’s 1997 “Guidance for Developing and Site

Safety Plan for Marine In Situ Burn Operations,” and a plan in compliance with 18 AAC

75.425 (e)(1)(c), Alaska regulations for oil spill contingency plans’ safety plans.

SMART: Special Monitoring of Applied Response Technologies

SOSC: State On-Scene Coordinator

Unpopulated Area: An area where people are not present within three miles of the burn operation.

Yellow Zone: Marginal Air Quality. Predicted concentration of particulates may exceed established

air quality standards.

How to Use In Situ Burning Guidelines for Alaska

The Alaska in situ burning guidelines are used by the Alaska Department of Environmental

Conservation, United States Coast Guard, and U.S. Environmental Protection Agency on-scene

coordinators to authorize an emergency in situ burn of oil. They may authorize burning when:

mechanical containment and recovery by themselves are incapable of controlling the oil spill,

burning is feasible, and the burn will lie a safe distance from populated areas. To receive

authorization, an applicant completes the “Application and Burn Plan” form (found in Appendix 1)

and submits it to the on-scene coordinators in the Unified Command. The on-scene coordinators

then complete the FOSC/SOSC Review Checklist in Appendix 2. The checklist includes the

following six steps: review of the completed Application to Burn Plan (Step 1); determine feasibility

of burning (Step 2); determine whether burn may be conducted at a safe distance from population

areas (Step 3); determine whether environmental and other considerations will be adequately

addressed (Step 4); review consultations and requests for authorization (Step 5); and make decision

on whether to authorize burn (Step 6).

NOTE: These guidelines were initially updated to meet the National Ambient Air Quality Standard

(NAAQS) of PM2.5 and 65g/m3

for public health and safety requirements. In 2006, the standard

was revised to 35g/m3. These guidelines are consistent with the revised national air quality

standard. However, air monitoring (in accordance with the SMART protocols) must be conducted

during the burn operation to ensure the standard is not exceeded for populated areas, and to

validate predictive models used in this document.

Note: The Unified Command can proceed with approving the burn operation as long as SMART

resources are en route or available within a reasonable timeframe.

Among the guidelines are distances that should separate populated areas from the burn to protect

the public health. The “safe distances” are designed to meet the most recent state and federal air

quality public safety regulatory standards in populated areas. Air monitoring must be conducted

(whenever there is a potential of impacting populated areas) to verify that safe distances and public

health and safety standards are maintained at all times during the burning operation. In uninhabited

areas, the safe separation distances are not necessary for burn authorization.

The guidelines include the following sections and appendices:

Overall background information is described in Section 1.

Technical background that supports the guidelines is included in Sections 2, 3 and 4.

The general guidelines for safe distances are described in Section 3 and Table 4.

Cook Inlet and North Slope alternative guidelines for safe distances are described in Section 3

and Table 5.

Public notification levels are described at the end of Section 3 and in Table 7.

Information on environmental considerations is included in Section 4.

Administrative Update: March 2018

The Application and Burn Plan is provided in Appendix 1.

The FOSC/SOSC Review Checklist is provided in Appendix 2.

A sample FOSC/SOSC Decision Document is provided in Appendix 3.

Class I Areas in Alaska are identified in Appendix 4.

A list of air quality monitoring equipment in Alaska is provided in Appendix 5.

Definitions of Fire Danger Ratings for Inland Areas are included in Appendix 6.

SMART Protocols for in situ burning can be accessed at:

https://response.restoration.noaa.gov/sites/default/files/SMART_protocol.pdf

4 Revision 1-August 2008



1. Introduction

Background and Technical Information

1. INTRODUCTION

Purpose and Scope

The guidelines identify (1) the Alaska Regional Response Team’s (ARRT’s) policy on the use of in

situ burning as a response tool; (2) the process to be used by the FOSC/SOSC through the Unified

Command to determine whether in situ burning is appropriate following an oil discharge; and (3)

entities to be consulted by the FOSC/SOSC to obtain input on a request to conduct an in situ burn.

The guidelines serve the following purposes:

Provide the FOSC/SOSC with a process that will help expedite in situ burning decision-making.

Ensure that stakeholders and other technical experts are consulted as appropriate.

Protect public health from smoke emitted from emergency burns.

Transfer the state open burn permit authorization role under 18 AAC 50.035 from the state air

quality regulators to the SOSC.

Incorporate most recent available criteria for human health protection.

Provide information on environmental considerations.

Provide a resource document for preparing in situ burning plans as part of the contingency plan

process, regulated under 18 AAC 75.425(e)(3)(G)(iii), (iv), and (v).

Provide a background for determining when to use the tool of in situ burning.

The guideline document is neither an operational nor a tactical manual. It does not provide a

contingency plan for an optional response tool, a site safety plan, nor an exhaustive literature

review.

Applicability

These guidelines apply to in situ burning of petroleum discharges during emergency response

anywhere in Alaska. This includes marine waters and inland areas and waters.

Background

In March 1989, the ARRT adopted the “Oil Spill Response Checklist: In Situ Burning” for use by a

party responding to a spill. The checklist was subsequently revised and approved by the ARRT in

July 1992. In February 1991, the ARRT approved the “Alaska Regional Response Team In Situ



1. Introduction

Burning Memorandum of Agreement: Beaufort and Chukchi Seas and Selected North Slope Areas.”

In 1994, the ARRT incorporated the In Situ Burning Guidelines for Alaska into its Unified Plan; the

In Situ Burning Guidelines for Alaska superseded both the checklist and the memorandum of

agreement. This version (Revision 1) updates the 1994 guidelines, but is not a pre-approval under

the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). Consultation, as

required by the NCP, is necessary.

In certain circumstances, the effectiveness of mechanical containment and removal is limited. In

these circumstances, the use of in situ burning, alone or in conjunction with mechanical and/or

chemical countermeasures, may minimize threats to public health and the environment.

Under the NCP, the FOSC can authorize the use of burning agents on a case-by-case basis after

obtaining concurrence from the U.S. Environmental Protection Agency and state representatives to

the regional response team and in consultation with the U.S. Department of the Interior (DOI) and

U.S. Department of Commerce (DOC) natural resource trustees when practicable. In Alaska, the

DOI and DOC ARRT representatives are the DOI and DOC natural resource trustee representatives,

respectively. From a federal perspective, “burning agents” must be authorized according to the

provisions of the NCP, 40 CFR Part 300.910. The use of in situ burning is regulated by Subpart

J of the NCP, the Clean Air Act, the Federal Water Pollution Control Act as amended by the Oil

Pollution Act of 1990, and State of Alaska law.

From a state perspective, in situ burning constitutes an open burn for which approval is required

under Alaska air quality regulations (18 AAC 50.065). By following these guidelines, the SOSC can

approve in situ burning. The state’s air quality regulations incorporate this document by reference

in 18 AAC 50.035.

In Alaska, federal and state agencies consider applications for in situ burning under the Unified

Plan and a unified command system that join the FOSC and SOSC in decision-making. The

Unified Plan states that “whenever there is an incident involving more than one agency with

jurisdiction, the Unified Command is implemented.”

Updates in this Revision

This is Revision 1 of the In Situ Burning Guidelines for Alaska. It updates the original guidelines

that were incorporated into the Unified Plan in 1994. Revision 1 includes the following changes:

Revision 1 is not a pre-approval under the NCP. Rather it provides for case-by-case

consideration of the use of in situ burning of petroleum discharges.

The safe distances recommended between an in situ burn and populated areas are refined.

See Section 3.

The “ISB Review Checklist” and “Application for ISB” in the 1994 guidelines are streamlined.

The new forms are “Application and Burn Plan” and “FOSC/SOSC Review Checklist.”

The new safe distance guidelines are based on the smoke plume’s predicted concentrations of

PM2.5. The 1994 guidelines were based on PM10 concentrations. The change takes into account the new National Ambient Air Quality Standards for PM2.5 that became effective in



1. Introduction

1997. See Section 3. These guidelines are consistent with the revised national air quality

standards (35g/m3

for PM2.5).

Revision 1 assumes that maintaining safe distances between populated areas and harmful

levels of PM2.5 will also provide an adequate buffer to protect populated areas from air toxics

and all other byproducts of combustion.

The new version of the smoke plume trajectory model, ALOFT-FT-Flat Terrain version 3.04 for

PC, distinguishes between flat, complex terrain, and water scenarios. This refinement is

reflected in the new safe distance guidelines. See Section 3.

Safe distance prediction uncertainty is expressed in graphs of mixing height and wind speed

effects in McGrattan et al. (1997). Predicted distances are no longer multiplied by a factor of 2

to produce safe distance guidelines.

Revision 1 considers the results of in situ burning studies reported in the proceedings of the

International Oil Spill Conferences and the Arctic and Marine Oil spill Program Technical

Seminars, in situ burning guidance of other Regional Response Teams, and guidance from the

National Response Team.

Revision 1 includes residue collection as a condition of authorization, when practicable.

Revision 1 includes, as a condition of authorization, requirements for visual monitoring and/or

sampling of the smoke plume (in accordance with the Special Monitoring of Applied Response

Technologies (SMART) protocols) during a burn where there is a potential to impact populated

areas. See Section 3.

The process for considering the use of in situ burning in all environments (inland and marine) is

addressed.

Discussions of the importance of in situ burning in Alaska and general issues of smoke,

residues, and toxicology are updated.

Revision 1 incorporates Endangered Species Act compliance in accordance with the “Inter-

agency Memorandum of Agreement Regarding Oil Spill Planning and Response Activities

Under the Federal Water Pollution Control Act’s National Oil and Hazardous Substances

Pollution Contingency Plan and the Endangered Species Act (ESA MOA)”.



1. Introduction




2. Operational Considerations

2. OPERATIONAL CONSIDERATIONS

The in situ burning operations discussion in this section supports Parts 1 and 2 of the Application and

Burn Plan and Steps 1 and 2 of the FOSC/SOSC Review Checklist. In Step 1, the FOSC/SOSC

decides whether in situ burning is an appropriate response option, when considering mechanical

containment and recovery and/or the use of dispersants. In Step 2, the FOSC/SOSC determines

whether in situ burning is feasible under the spill circumstances.

In Situ Burning in Relation to Mechanical Recovery

When mechanical recovery is unfeasible, ineffective, and/or insufficient, removing oil from the water

or from land by in situ burning may provide increased protection for fish, wildlife, and sensitive

environments, as well as commercial, subsistence, historic, archaeological, and recreational

resources. In situ burning may (1) prevent the resources from coming into contact with spilled oil;

(2) reduce the size of the spill and thus the amount of spilled oil affecting natural resources and/or

historic properties; (3) allow the natural resources to recover more quickly; and/or (4) provide the

most effective means to remove oil from water prior to shoreline impacts in broken ice conditions, in

remote or inaccessible areas, and/or when containment and storage facilities are overwhelmed.

Optimal Conditions for Burning

Table 1 summarizes the optimal conditions for in situ burning. Oil thickness and emulsification have

the greatest effects on ignition and burn efficiency. Most types of oil burn readily. However, the

difficulty of establishing and maintaining slick thickness of lighter oils and achieving ignition of heavier

oils make in situ burning less feasible for some oils, such as diesel and Bunker C.

Oil Thickness and Containment

Thicker layers of oil more readily ignite and sustain a burn. A minimum thickness of 2 to 3 millimeters

of oil may be required for ignition (ASTM 2003) regardless of oil type. The thickness necessary for

successful ignition increases with weathering and viscosity of oils. For example, minimum ignitable

thicknesses for Alaska North Slope crude oil are estimated at 1 millimeter for fresh, volatile crude;

(S.L. Ross 1997). Once the slick has been ignited, combustion is sustained as long as the slick

maintains some minimum thickness, estimated to be about 1 millimeter (ASTM 2003).

Thicker layers of oil also burn more efficiently. The U.S. Environmental Protection Agency (1991)

reported that in a slick of 10 millimeters thickness, approximately 80 to 90 percent of the oil burned.

In a slick of 100 millimeters thickness, approximately 98 to 99 percent of the oil burned.


Table 1 Optimal Conditions for Effective Burning of Alaska North Slope Crude Oil

Considerations Conditions for Effective Burning

Oil thickness Minimum 2 to 3 mm for ignition.

Efficiency (percent of oil in the boom removed by burning) increases with

increased thickness.

Emulsification Less than 25% water content.

Efficiency and ease of ignition decrease with increasing water content.

Weathering Relatively fresh oil (less than 2 to 3 days of exposure) is best for ignition.

Difficulty of ignition increases with further weathering.

Weathering times may vary among crude oil types and weather conditions.

Wind Less than 20 knots for ignition.

Waves Waves impact boom effectiveness and combustion primarily by causing splash-

over.

Less than 3 ft in choppy, wind-driven seas is optimal (short-period waves, less

than 6 seconds).

Less than 5-6 ft in large swells is optimal (i.e., long-period waves, greater than

6 seconds).

Currents Less than 0.75 knots relative velocity between the fire boom and the water is

optimal to reduce oil entrainment beneath the boom.

Ice Variable effects depending upon the nature and concentration of the ice.

Where ice contains the oil and prevents it from spreading, the burn can remove a

high percentage of the naturally contained slick.

Isolated floes may interfere with booming operations by filling collection areas,

preventing oil from building up within the collection area, blocking the flow of oil to

skimmers, and even damaging containment booms and skimmers. Likewise, ice

can build up within fire booms and preclude the effective use of burning within the

boom.

Adapted from Alyeska Pipeline Service Company, 1996.

In many situations, spilled oil is concentrated by containment to achieve the optimal thickness level.

Fire-resistant boom contains oil best when deployed in a catenary mode and towed at speeds of less

than 0.35 m/s (~3/4 knot) (ASTM 2007). At greater speeds, oil is lost under the boom by entrainment.

Ice concentrations of approximately 8 tenths coverage or greater may provide good containment for oil

trapped between ice cakes and floes (Industry Task Group 1984). In pack ice conditions in Cook Inlet

and on the North Slope, oil can be contained by the reduced area available for spreading, the cold

surface waters, and the reduced influence of wind. During field tests conducted by Buist and Dickins

(1987), ice cover “dramatically reduced” the spread of oil.


Solid ice on the North Slope can contain oil as follows (Industry Task Group 1984):

Landfast sea ice provides barriers to the spread of oil spilled on or beneath it.

During the solid-ice period, cold air temperatures, surface roughness, and snow limit the spread

of oil and reduce evaporative losses, thus enhancing in situ burning operations.

Oil on early spring ice accumulates in melt pools, and subsurface oil slowly migrates to the

surface through brine channels and cracks.

During freezeup, spilled oil becomes contained by new thin or slush ice.

Guenette and Sveum (1995) found that fresh crude and emulsions can be burned uncontained on

open water. The wind-herding effect of the burn allows the slick to maintain sufficient thickness to

burn at similar efficiencies to contained burns. The burning, uncontained emulsion slicks spread

significantly less than the burning, uncontained fresh crude slicks.

Shorelines also sometimes serve as natural containment for oil for in situ burning (ASTM 2003).

Emulsification

Emulsification and water entrainment decreases ignitability, burn rate, and burn efficiency (Buist et al.

1997). In a series of small-scale test burns, Buist (1989) concluded that for a given thickness of oil,

ignition times increased only slightly with weathering but increased dramatically with emulsification.

Although not enough data are available to determine the specific water percentage that limits ignition,

indications are that oil containing less than about 25 percent water will burn, while emulsions containing

70 percent water cannot be ignited (ASTM 2003).

Alaska Clean Seas conducted test burns on weathered, emulsified crude oil (Buist et al. 1996, 1997).

The tests showed that Alaska North Slope crude cannot be ignited at water contents greater than 25

percent, although the results varied widely among oil types (Buist et al. 1995b). Endicott crude

containing up to 25 percent water burned well, even with weathered oil. Point McIntyre crude and

IFO-30 fuel oil with various water contents, however, was difficult to burn, even with no weathering.

Oil spill models such as the ADIOS model (NOAA 2005) and S.L. Ross (1997) describe

emulsification rates of oils.

Weathering

Weathering (i.e., evaporation) decreases the ignitability and efficiency of in situ burns (Buist et al.

1996). Researchers have found that weathering resulted in the loss of volatile compounds, more

difficult ignition, and slower combustion, but in some cases, a higher proportion of oil burned (Fingas

and Punt, 2000). Weathering up to about 20 percent appeared not to affect the burn efficiency of

crude oil. Between 20 and 35 percent, weathering increased burn efficiency, but beyond 35 percent

efficiency declined.


Waves

In test burns, wave energy increased the burn rate of thicker unemulsified slicks (10 to 20 millimeters) of

fresh and weathered Alaska North Slope crude. However, waves had little effect on the burn rate of

thinner slicks (2 to 5 millimeters). Although waves decreased the burn rate of emulsions of

10.3 percent evaporated Alaska North Slope crude, they had little effect on the burn rate for

29.1 percent evaporated oils with high water content (Buist et al. 1997).

Burn Volumes

Burn rate is relatively independent of physical conditions and oil type. Oil burns at a rate of about

1.7 gallons/square foot/minute, or about 100 gallons/square-foot/day (ASTM 2003). This means that

a single 500-foot fire boom, positioned in a U configuration to intercept a spill, provides enough burn

area to sustain a burn rate of 15,000 barrels per day. Three such U configuration booms working

in a collection-relocation-and-burn mode could burn approximately 8,000 barrels of oil during a 12-hour

period, with only one U configuration burning at a time (Fingas and Punt, 2000).

Residues

The responsible party or applicant is required to have a plan for residue collection. Section 4

discusses the toxicological aspects of burn residues. The toxicological properties and effects of the

residue demonstrate the need and importance of a residue recovery plan which is an operational

requirement.

Volume and Chemical Composition. The volume of residues produced by in situ burning is

much lower than the original volume of the oil (Table 2), and is altered in chemical composition and

physical properties from the oil. During a burn, the lighter, lower-boiling-point hydrocarbons are

eliminated, while the heavier, higher-boiling-point hydrocarbons are concentrated in the residue.

(Trudel et al., 1996) found that the majority of burn residues are composed of non-volatile compounds with

boiling points greater than 538C. Burn residues from crude oils contained no volatiles with boiling

points less than 204C; all contained some portion of the medium-volatility compounds with boiling

points between 204C and 538C. Burn residues may be less toxic than the parent oils, because

the volatiles such as benzene, naphthalene, and benzopyrenes are nearly absent (S.L. Ross, 1997).

Environment Canada carried out several series of burns on heavy oils and characterized the residues

fully (Fingas et al., 2005). They found that the PAHs in the residue were pyrogenic – deriving from the

fire and there were few residual PAHs from the oil itself. Models were developed to predict the overall

composition and density of the residue.


Table 2 Residue Produced During the Newfoundland Offshore Burn Experiment

Variable Burn 1 Burn 2

Volume of oil discharged (m3) 48.3 28.9

Residue in fireproof boom after the burn (m3) 0.2 (max.) 0.1 (max.)

Residue in backup boom after the burn (m3) 0.2 (max.) 0.3 (max.)

Burn efficiency >99% >99%

Density (g/mL at 15C) (density of sea water is 1.025) 0.9365

Data from Fingas et al., 1994.

Physical Properties. Burn residues are more dense and viscous than oil. During two test burns

with Alaska North Slope crude oil, one with fresh, unweathered oil and the other with weathered,

emulsified oil, the residues in both cases sank after the residue had cooled (Buist et al. 1995a and b).

Table 3 lists the densities of Alaska North Slope crude oil residues after several test burns.

Table 3 Characterization of Residues from Laboratory Test Burns of

Alaska North Slope Crude

Variable

Thickness of Oil Slick

5 cm 10 cm 15 cm

Burn efficiency 84.9% 91.6% 90.9%

Density (in g/cm3) at 15C (density of

normal sea water is 1.025)

1.025 1.075 1.045

Adapted from Tables 4 and 5, Buist et al., 1995.

Residues from in situ burns vary greatly in consistency. Tests on Alaska North Slope crude oil

produced residues ranging in consistency from a “semi-solid not unlike cold roofing tar” for fresh,

unweathered oil, to residue in the form of a “brittle solid” for weathered, emulsified oil (Buist et al.

1995a and b). The 15,000- to 30,000-gallon test burn during the Exxon Valdez spill produced about

300 gallons of “stiff, taffy-like residue that could be picked up easily” (Allen 1990). Emulsion residues

can be less viscous and more difficult to recover than residues from fresh crude. Burns from heavy

oils resulted in residues that were often solid and glassy (Fingas et al., 2005). Floating, tar-like

residue can be removed manually with sorbents, nets, or other similar equipment. However, recovering

the less-burned residue from emulsion burns, which can include unburned oil and emulsions, may

require special equipment (Guenette and Sveum 1995). Residues of some oils, including Alaska

North Slope crude, may sink as they cool, even in sea water. It should be noted that the cooling rate

of the residue is slow and this may allow a few hours to recover the residue before it sinks (Fingas et

al., 2005).


Monitoring, Sampling, and Trial Burns

In situ burn operations should incorporate constant visual monitoring of the smoke plume’s behavior.

The FOSC/SOSC will jointly ensure the monitoring of smoke plumes for all in situ burns. Burn

monitoring teams will be quickly organized, and if possible, deployed prior to conducting any trial or

operational burn. If practicable, this will include, for all burns, visual monitoring of the smoke plume’s

behavior. In addition, air monitoring will be conducted during the burn operation whenever there is a

potential to impact populated areas.

The Unified Command should consider additional safeguards when appropriate such as use of the

NRT’s SMART protocols for monitoring burns.

(See https://response.restoration.noaa.gov/sites/default/files/SMART_protocol.pdf

Information from burn monitoring will be continuously evaluated to ensure the burn is being conducted

safely. Weather and sea conditions will also be continuously monitored. In the event burning

conditions become unfavorable and/or if it poses a threat to safety or public health, the burn will be

extinguished.

A trial burn should be conducted (if practicable) to verify predicted plume direction and dispersion

distance downwind before authorizing continued burning operations. When performing inland burn

operations the FOSC and SOSC will utilize the Incident Command System / Unified Command

System to coordinate with appropriate land managers and other stakeholders (e.g., borough and city

officials).

Federal and/or State natural resource trustees may request, on case-by-case basis, that natural

resource trustee representative(s) be included on the in situ burn monitoring team (e.g., if threatened

or endangered species are, or may be, present in the area; if burning is conducted on Federal or

State-managed lands; or if in situ burning is conducted near a migratory bird colony). See Appendix

5 for a list of air quality monitoring equipment in Alaska.

Safety of Personnel

A site safety plan for in situ burning is required. Occupational Safety and Health Act regulations (29

CFR 1910.120) specify that employers are responsible for the health and safety of employees in

response situations. Generally, the in situ site safety plan is an appendix to an umbrella site safety

plan covering the entire spill response (NRT 1997b). The combination of the general site safety plan

and the appendix site safety plan for in situ burning must include the elements listed in 29

CFR 1910.120(b)(4).

Incorporated here by reference for guidance is “Guidance for Developing a Site Safety Plan for

Marine In Situ Burn Operations,” written by the National Response Team’s Science & Technology

Committee (1997a). Alyeska Pipeline Service Company’s “Supplemental Information Document:

Burning as a Response Tool” (1996) also provides suggestions. There are a number of other,

excellent resource documents available to assist with decision-making.

Safety concerns associated with in situ burning include the following:



Fire hazard. In situ burns are monitored to ensure that fire does not spread to adjacent

combustible material. Care is taken to control the fire and to prevent secondary fires. Personnel

and equipment managing the process are protected.

Ignition hazard. Ignition of the oil slick receives careful consideration. Involvement of aircraft for

aerial ignition with gel or other ignition methods is coordinated. Weather and water conditions

are kept in mind, and safety distances are set and adhered to.

Extinguishing and controlling the burn. An in situ burn on water may be extinguished by

increasing the tow speed so that oil is entrained in the water, by slowing down to reduce the

rate at which the boom encounters oil, or by releasing one side of the oil containment boom.

In the test burn during the Exxon Valdez spill, Allen (1990) noted that the area of the burning

oil was easily controlled by adjusting the speed of the towing vessels.

Vessel safety. In situ burning at sea involves several vessels working in relatively close

proximity to each other. Vessels and crews working in these conditions should have practiced

the techniques involved with in situ burning.

Other hazards. Training and safety guidelines are a part of all in situ burning operations.

Working under time constraints may impair judgment or increase the tendency to attempt

costly shortcuts. In Alaska, personnel may be exposed to extreme cold. Personnel may

also be exposed to extreme heat from the fire.

Wildlife

In accordance with the Endangered Species Act (ESA) Memorandum of Agreement (MOA)

emergency consultation process, when a threatened or endangered species and/or their critical

habitat(s) are, or could be present, in the area affected by a proposed in situ burn, U.S. Department

of Commerce-National Marine Fisheries Service and/or DOI-Fish and Wildlife Service

representatives will provide the FOSC with timely recommendations to avoid and/or minimize

impacts to listed species and/or their critical habitat. These recommendations may include

horizontal and vertical separation distances between (1) in situ burning-related aircraft/motorized

vessels and concentrations of listed species and/or portions of their critical habitat (e.g., sea

lion haul outs); and/or (2) the in situ burn and concentrations of listed species and/or portions

of listed species’ critical habitat (e.g., sea lion rookeries). [Note: When a threatened or

endangered species and/or their critical habitat(s) are, or could be present in an area affected

by incident-related response activities, the FOSC needs to initiate emergency consultation by

contacting the NOAA and/or the DOI ARRT contacts to request endangered species expertise.]

These recommendations may also be made where non-listed species are present in, or adjacent

to, the area where an in situ burn is proposed.

In addition, depending on the circumstances of an incident, Federal and State natural resource

trustees may recommend that, where possible, wildlife that are present in, or adjacent to, the

area where an in situ burn is proposed, be deterred away from the area.





3. Safe Distance

3. SAFE DISTANCE

The safe distance discussion in this section supports Part 3 of the Application and Burn Plan

and Step 3 of the FOSC/SOSC Review Checklist. In Step 3, of the decision-making process,

the FOSC/SOSC determine whether the burn may be conducted at a safe distance from

populated areas. In situ burning is not authorized if it does not meet public health regulatory

standards. The FOSC/SOSC may use Table 4 for general safe distance guidance. They may use

Table 5 in place of Table 4 in Cook Inlet and on the North Slope. In Step 6 of the FOSC/SOSC

Review Checklist, the FOSC/SOSC determine whether to conduct an in situ burn. A decision

to conduct an in situ burn may include conditions to protect human health.

The “safe distances” are designed to meet the most recent state and federal air quality public

health regulatory standards in populated areas. Air monitoring (in accordance with the SMART

protocols) must be conducted during the burn operation whenever there is a potential of impacting

populated areas to ensure the public health and safety standard is not exceeded.

In unpopulated areas, the safe separation distances are not necessary for burn authorization.

For populated areas on flat land and on water within 3 miles of shore, the FOSC/SOSC, working

within the Unified Command, may authorize burning 3 miles or more upwind. The FOSC/SOSC

may also authorize burning on marine water that is 3 miles or more from shore and 1 mile

or more upwind from populated areas.

A computer model has predicted the greatest downwind distance at which the smoke plume’s

particulate matter of 2.5 microns or less in diameter (PM2.5) diminishes to 65 micrograms per

cubic meter averaged over one hour at ground level in flat terrain. At that distance,

concentrations of soot and chemicals in the smoke are well below the National Ambient Air

Quality Standards. In unpopulated areas, the safe separation distances are not necessary

for burn authorization. To help determine whether an area that could be affected by an in situ

burn smoke plume is unpopulated, the Unified Command will consult with land managers and

(to the extent practical) land owners of the area to help determine whether there may be

individuals using the area for activities including, but not limited to, fishing, hunting, berry

picking, camping, boating, backpacking, and/or conducting research. The Unified Command

may require further verification by aerial reconnaissance or some similar means.

Note: Another alternative to using computer models is to use predictors based on actual

fires. Such a system is presented in Environment Canada’s handbook on in situ burning

(Fingas and Punt, 2000). The advantages of this system are that it is based on actual burns

and factors in many conditions. The disadvantage of this system is that exact weather

conditions or terrain cannot be factored in. On the other hand, the weather conditions prevalent

at the time of the actual burns represent the typical conditions under which one might burn.

In some conditions in populated areas, the FOSC/SOSC may authorize in situ burns without

relying on computer predictions. The predictions apply only to distances beyond 1 kilometer and

to flat terrain. However, the FOSC/SOSC may authorize in situ burns closer to populated areas

and in hilly terrain, if their best professional judgment is that the smoke will not expose populated

areas



3. Safe Distance

to emissions exceeding the National Ambient Air Quality Standard concentrations averaged over

one hour.

The Public Safety Criterion

The safe distance separating populated areas from in situ oil burns is the downwind radius from

the fire at which smoke PM2.5 concentrations at the ground diminish to 65 micrograms per cubic

meter averaged over one hour. The safe distance guidelines are based on the predictions of a

computer model, ALOFT-FT-Flat Terrain model 3.04. The safe distance meets the National

Ambient Air Quality Standards for particulate matter in flat terrain and is also used as the indicator

that populated areas will not be exposed to unsafe levels of all other smoke components.

As noted previously, these guidelines were initially updated to meet the National Ambient Air Quality Standard (NAAQS) of PM2.5 and 65g/m

3 for public health and safety requirements.

The standard was subsequently revised to 35g/m3. These guidelines are consistent with the revised

national air quality standard. However, when practicable air monitoring (in accordance with the

SMART protocols) must be conducted during the burn operation whenever there is a potential of

impacting populated areas. This action is necessary to ensure the standard is not exceeded for

populated areas, and to validate predictive models used in this document.

Computer modeling was used so that real-time air sampling of the smoke plume is not necessary

during an in situ burn. However, visual monitoring of the plume is required. Fifty-six scenarios in

Cook Inlet and the North Slope were modeled by the program, and the worst-case predictions

were used to develop the safe distances. Incorporated here by reference is “In Situ Burning Safe

Distance Predictions with ALOFT-FT Model” (Bronson 1998), which explains how the safe

distances were predicted.

PM2.5 reflects the size of particulates that pose the greatest human health hazard. The National

Response Team noted that if the particulate matter standard is “exceeded substantially, human

exposure to particulates may be elevated to a degree that justifies terminating the burn. If

particulate levels are generally below the limit, with only minor transitory incursions to high

concentrations, there is no reason to believe that the population is unacceptably exposed above

the accepted National Ambient Air Quality Standard for the burn” (NRT 1995). Furthermore, safe

PM2.5 concentrations indicate safe concentrations of other emissions (Bronson 1998).

The factor of 2 that was applied to the downwind distance predictions in the 1994 in situ burning

guidelines (ARRT 1994) is replaced as the means to incorporate uncertainty in the safe distances.

Uncertainty in the predictions is now shown in the diagrams introduced by McGrattan et al. (1997)

and discussed by Bronson (1998).



3. Safe Distance

Safe Distance in Populated, Flat Terrain

The FOSC/SOSC determines whether the flat terrain safe distance guidelines apply through

the use of topographic maps and on-scene weather information. Among the conditions of

authorization is that the in situ burn lies a safe distance from populated areas.

Table 4 lists the general safe distances separating an in situ burn and downwind, populated areas

on flat terrain using the computer model. Figures 1 through 4 show bird’s-eye and cross-sectional

views of the safe distances.

Table 4

Safe Distances Between In Situ Burns and Downwind Populated Areas in Flat Terrain

(see Table 5 for Cook Inlet and North Slope Safe

Distances)

Location of Fire Green Zone Yellow Zone Red Zone

Flat terrain on land

Water <3 miles from shore >3 miles 1 to 3 miles <1 mile

Water >3 miles from shore

>1 mile

not applicable

<1 mile

The green zone safe distance on water more than 3 miles from shore, is 1 mile from populated areas. In these circumstances, the green zone originates immediately after the red zone without a buffering yellow zone. Yellow zones are used only in populated areas where there is potential exposure.

The green zone safe distance on land or on water less than 3 miles from shore is 3 miles from populated areas. Burning at a green zone safe distance from populated areas is acceptable following Level 1 public notification as outlined under “Notification Levels”.

The yellow zone distance extends from 1 to 3 miles downwind of an in situ burn, and within

45 degrees of the smoke plume, when the burn is on land or on water within 3 miles of shore.

The quadrant shape of the zone protects populated areas from smoke subjected to minor wind

shifts. The FOSC/SOSC may authorize burning following Level 2 and Level 3 public notifications,

warning, and sheltering in place or evacuation as outlined under “Notification Levels”.

The red zone distance is within 1 mile of any in situ burn and within 45 degrees of the smoke

plume. The FOSC/SOSC may authorize burning in the red zone following public notifications,

warnings, and sheltering in place or evacuation, and if the FOSC/SOSC’s best professional



judgment supports the expectation of PM2.5 less than 65 micrograms per cubic meter, 1-hour

average in populated areas. (See “Notification Levels”)

The red zone radius takes into account that the risk of smoke exposure becomes greater close

to the fire. In addition, the ALOFT-FT model does not predict the behavior of smoke close to the

fire

3. Safe Distance

before it lofts. The red zone downwind boundary also lies downwind of the expected in situ burn

operations site safety area. For example, a 1,000-foot radius around an in situ burn of oil in a fire

boom may be designated as the worker site safety zone by the site safety officer.

The Table 4 rules apply only in the following situations:

In the vicinity of populated areas

For a burn of any size from a single source

For simultaneous burns less than 100 yards apart

The Table 4 rules do not apply in the following situations:

In unpopulated areas

In situ burns less than 3 miles upwind of terrain that rises more than 10 percent of the

mixing layer height

For simultaneous burns more than 100 yards apart



45o

45o

3. Safe Distance

Figure 1: Zones for In Situ Burns on Populated Flat Land, and on Water Within 3 Miles of Shore

The dashed circle shows an example of a 1,000-ft radius site safety zone for workers, determined under a separate site safety plan.

Green Zone

Yellow Zone

1 mile

3 miles

Red Zone



Intentionally blank (color figure on front)



Red Zone Green Zone

Yellow Zone

1 2

Downwind distance from fire (miles)

3 4

Figure 2. Example of Zones for an In Situ Burn Over Land or on Water Within 3 Miles of Shore

ALOFT-FT model projection for a burn of 5,000 square feet of oil in Cook Inlet during the summer.

3. Safe Distance

3500

3000

2500

2000

1500

1000

500

0

1 2 3 4 5 6 7 8 9 10 11 12


1

0

PM2.5 concentrations (micrograms per cubic meter)

200 150 100 65

Red Zone

Yellow Zone

Green Zone

Altitude (

mile

s)

Altitude (

feet)



3. Safe Distance


3. Safe Distance

Figure 3: Zones for In Situ Burns on Water more than 3 Miles from Shore

The dashed circle shows an example of a 1,000-ft radius site safety zone for

workers, determined under a separate site safety plan.



Green Zone

1 mile

Red Zone

3. Safe Distance




3. Safe Distance

Figure 4. Example of Zones for an In Situ Burn on Water at least 3 miles from Shore

ALOFT-FT model projection for a burn of 5,000 square feet of oil in Cook Inlet during the summer.

3000

2500

2000

1500

1000

500

0

1 2 3 4 5 6 7 8 9 10 11 12


1

0

1 2 3 4




PM2.5 concentrations (micrograms per cubic meter)

200 150 100 65

Red Zone

Green Zone

Altitude (

feet)

A

ltitu

de (

mile

s)

Red

Zone Green Zone

3. Safe Distance




3. Safe Distance

Authorization in Cook Inlet and on the North Slope

Table 5 summarizes the results of computer modeling of in situ crude oil burns involving

meteorological conditions typical of Cook Inlet and of the North Slope in flat terrain. The table lists

the greatest downwind distances at which concentrations of PM2.5 are expected to reach 65

micrograms per cubic meter at ground level. The FOSC/SOSC may use the predictions in Table 5

as safe distances for burns over flat terrain in Cook Inlet and on the North Slope instead of the

green zone distances in Table 4.

PM2.5 National Ambient Air Quality Standard

The PM2.5 safe distance criteria in these guidelines were revised in the late 1990s to reflect the

National Ambient Air Quality Standards’ 65 microgram per cubic meter threshold. The standard

was subsequently revised to 35g/m3

in 2006. These guidelines are consistent with the latest

revision of the fine particulate standard. To enhance the FOSC/SOSC’s understanding of fine

particulate levels downstream of a burn, air monitoring (in accordance with the SMART protocols)

must be conducted during the burn operation whenever there is a potential of impacting populated

areas to ensure the standard is not exceeded.

The 1-hour period follows the recommendations of the National Response Team Science &

Technology Committee (1995) and reflects the lack of a formal short-term exposure limit for

particulate matter.

The national primary and secondary ambient air quality standards for particulate matter now include

the standard of 35 micrograms per cubic meter 24-hour average concentration measured in the

ambient air as PM2.5. The PM2.5 24-hour standard is met when the 3-year average of the annual

98th percentile concentration values of measurements over 24-hour periods at monitoring sites is

less than or equal to 65 micrograms per cubic meter.



Table 5

ALOFT-FT Predictions of Downwind Safe Distances for Ground-Level PM2.5

Concentrations of 65 Micrograms per Cubic Meter over Flat Terrain. Simulations are based on atmospheric conditions typical of Cook Inlet and the North Slope.

Burning Area

Season

Regional

Wind

Downwind Distance (miles)

Source of

Meteorological Data Speed (knots)

Land Water

8 <0.6 <0.6

Summer Cook Inlet 16 1.5 <0.6

2,500 square feet 23 1.8 <0.6

North Slope 8, 16, 23 <0.6 <0.6

Winter Cook Inlet and 8, 16 <0.6 <0.6

North Slope 23 0.9 <0.6

8 <0.6 <0.6

Summer Cook Inlet 16 1.2 <0.6

5,000 square feet 23 2.4 <0.6

North Slope

Winter Cook Inlet and

North Slope 8, 16, 23 <0.6 <0.6

10,000 square feet

Summer and

Winter

Cook Inlet and

North Slope

16

<0.6

<0.6

Adapted from Bronson, 1998.

Consideration of Moving Source

The FOSC/SOSC may consider that a moving in situ burn may expose populated areas to less

smoke than a stationary fire. Even in a yellow zone, populated areas may not become exposed to

smoke for very long if the smoke plume is transiting over a population.

For example, the smoke from a continuous in situ burn in Cook Inlet may blow over the city of

Kenai, borne by a wind from the west. Concurrently, the tidal current carries the fire and its smoke

plume southward at several knots. The width of the plume passes over a residential area in a

matter of 15 or 20 minutes. Thus, at a point in Kenai where the smoke’s PM2.5 concentration equals

35 micrograms per cubic meter, the plume’s short duration there brings the 1-hour average

exposure well below 35 micrograms per cubic meter.



3. Safe Distance

Conditions of Authorization

An authorization to conduct an in situ burn as practicable, includes:

1. Visually monitoring the resulting smoke plume.

2. Collecting the resulting burn residue.

3. Notifying and/or warning populated areas in proximity to any of the three safe distance

zones.

4. Other conditions, as needed, to protect human health as imposed by the FOSC/SOSC.

5. Air monitoring (in accordance with the SMART protocols) whenever there is a potential of

impacting populated areas.

In addition, an authorization to conduct an in situ burn may also include other requirements, such

as the inclusion of natural resource trustee representative(s) on the in situ burn monitoring team.

Notification System

The notification system is in place for the possibility that the modeled in situ burn smoke plume

does not dissipate as expected. Four warning levels are to be used which correspond to the air

quality standards listed in Table 7 below. Methods for notifying populated areas may include, but

are not limited to: radio and television broadcasts; aircraft advisories; broadcasts to mariners; road

closures; marine safety zones; and use of handheld radios, cell phones, satellite phones, and/or

fixed or rotary-wing aircraft.

The notifications may also be used for sheltering in-place or evacuating small numbers of people

for a short period of time (e.g., fishermen, hunters, backpackers, recreational boaters, rural

residents, offshore platform operators, pump station and/or highway camp personnel).

Notification Levels

Level 1, general notification, is public notification/warning to people in populated areas within or

near the green, yellow, and red zones that burning is (or will be) occurring and the area is to be

avoided for a specific period of time. The FOSC/SOSC will implement Level 1 notification upon

their discretion, or when modeled air emission patterns indicate a particulate matter level greater

than state air quality alert/warning levels.

Level 2, alert notification, is public notification/warning involving a medical alert to persons with

existing conditions that put them at risk to air quality degradation. It is used when the ALOFT-FT

model predicts airborne PM2.5 concentration is anticipated to exceed 65 micrograms per cubic

meter 1-hour average in a populated area. The FOSC/SOSC will implement Level 2 notification

upon their discretion, or when modeled air emission patterns indicate a particulate matter level

greater than state air quality alert/warning levels.

Level 3, warning notification, is public notification/warning in the yellow zone for in-place sheltering

for a specified period of time. The FOSC/SOSC will implement Level 3 notification upon their



discretion, or when modeled air emission patterns indicate a particulate matter level greater than

state air quality alert/warning levels.

Level 4, emergency notification, is public notification/warning that includes the evacuation/relocation

of small numbers of people for a specific period of time from within the yellow and/or red zones.

The FOSC/SOSC will implement this emergency notification at their discretion, or when modeled air

emission patterns indicate a particulate matter level greater than state air quality alert/warning

levels. The authority to order such an evacuation is vested in local government or, if no local

government exists, state officials. In the event there are individuals on Federally-managed lands,

the FOSC will work with the appropriate land manager(s) to implement temporary

evacuation/relocation and closure procedures.

It should be noted that in situ burns authorized in accordance with these guidelines, using a safe

distance, should not ordinarily require Level 2, 3, or 4 notifications.

Post-Authorization Requirements

1. A Unified Command decision document will be generated specifying conditions for approval

of the in situ burn operation. (See Appendix 3 for a sample decision document)

2. An evaluation of the ISB operations will be included in the Unified Command after action

report as required by the NCP.



4. Public Health and the Environment

4. PUBLIC HEALTH AND THE ENVIRONMENT

Information on public health considerations in this section provides background information in

support of Part 3 of the Application and Burn Plan and Step 3 of the FOSC/SOSC Review Checklist.

In Step 3, the FOSC/SOSC determine whether the burn may be conducted at a safe distance from

populated areas. Information on environmental considerations in this section supports of Step 4 of

the FOSC/SOSC Review Checklist. In Step 4, the FOSC/SOSC receive input and determine whether

potential effects of an in situ burn on environmental (and other) considerations will be adequately

addressed.

Public Health Considerations

Smoke from in situ burns contains chemicals and particulates that may be toxic, much like emissions

from motor vehicles, power plants, wood stoves, and slash burning.

Table 6 lists the air quality thresholds for many smoke plume components. Table 7 describes the

health effects associated with the pollutants.




Table 6 Air Quality Standards

Contaminant (units)

Averaging Periods

Annual 24-hour 8-hour 3-hour 1-hour

National Ambient Air Quality Standards and Alaska State Regulatory Standards

PM2.5 (g/m3) 15 *65 — — —

PM10 (g/m3) 50 150 — — —

CO (g/m3) — — 10 — 40

SO2 (g/m3) 80 365 — 1,300 —

NO2 (g/m3) 100 — — — —

OSHA Permissible Exposure Limits

Total particulates (mg/m3) — — 15 — —

Respirable particulates (mg/m

3)

— — 5 — —

CO (ppm) — — 50 — —

**SO2 (ppm) — — 5 — —

***NO2 (ppm) — — 5 — —

CO2 (ppm) — — 5,000 — —

PAH (mg/m3) — — 0.2 — —

Benzene (in VOC) (ppm) — — 1 — —

Adapted from Table 2, McGrattan et al., 1997, and Annex D, NRT, 1997b.

*NOTE: These guidelines were initially updated to meet the National Ambient Air Quality Standard

(NAAQS) of PM2.5 and 65g/m3

for public health and safety requirements. In 2006, the standard

was revised to 35g/m3. These guidelines are consistent with the revised national air quality

standard. However, air monitoring (in accordance with the SMART protocols) must be conducted

during the burn operation whenever there is a potential of impacting populated areas.

**NAAQS has a secondary standard for sulfur dioxide (SO2) for 3-hour average at 0.5 ppm or 1,300

g/m3.

***The OSHA PEL of 5 ppm for nitrogen oxide (NO2) should not be exceeded at anytime.



Table 7 Air Quality Index Values and Associated Health Effects.

4. Public Health and Environment

existing heart or lung

Persons with existing heart

PM2.5 pollutant levels are pending with EPA. Proposed AQI revision as of April 2008



Index

Air Quality Level (Public

Notification Level)

Pollutant Levels

Health Effect

General Health

Cautionary

Value PM2.5

(24-hour)

µg/m3

PM10

(24-hour)

µg/m3

SO2

(24-hour)

µg/m3

CO (8-hour)

ppm

O3

(1-hour) ppm

NO2

(1-hour) ppm

Descriptor Effects Statements

500

Significant Harm

280

600

2620

50

0.6

2.0

Premature death of ill and elderly. Healthy people will experience adverse symptoms that affect their

All persons should remain indoors, keeping windows and doors closed. All persons

400

Emergency

(Level 4)

210

500

2100

40

0.5

1.6

Hazardous normal activity.

Premature onset of certain diseases in addition to

should minimize physical exertion.

Elderly and persons with existing diseases should

300

Warning (Level 3)

140

420

1600

30

0.4

1.2

Very Unhealthy

significant aggravation of symptoms and decreased exercise tolerance in healthy persons.

stay indoors and avoid physical exertion. General population should avoid outdoor activity.

200 Alert

(Level 2) 55 350 800 15 0.2 0.6

Significant aggravation of symptoms and decreased exercise tolerance in

Elderly persons with

100

cNAAQS

(Level 1)

35

150

365

9

0.12

a Unhealthy

persons with heart or lung disease, with widespread symptoms in the healthy population.

diseases should reduce physical activity.

50

50 % of NAAQS

15

50 80

b

4.5

0.06

a

Moderate

Mild aggravation of

symptoms in susceptible or respiratory ailments

0

0

0

0

0

0

a

Good

persons, with irritation symptoms in the healthy population.

should reduce physical exertion and outdoor activity.

a No index values reported at concentration levels below those specified by “Alert Level” criteria.

b Annual primary NAAQS.

c General Notification

Source: Centers for Disease Control


Particulates. Oil burns produce soot equal to 0.1 to about 3 percent of the mass of the burned

oil (Fingas and Punt, 2000). In most large-scale burns, not enough air is drawn into the fire for

complete combustion. The burn continues under “starved combustion,” and produces a thick,

dense, black plume of smoke composed of partially-burned byproducts in particulate (soot) and

gaseous form.

Particulates are small pieces of solid materials (e.g., dust, soot) or liquid material (e.g., mist, fog,

spray) that remain suspended in the air long enough to be inhaled. Particulate size plays a

crucial role in health effects, because it affects how far the particles travel before they settle out of

the air and how deeply they are inhaled into the lungs. Particulates larger than 10 microns in

diameter settle 1 foot in less than a minute in still air, so they tend to settle in the environment

quickly and generally are not inhaled. Particulates 0.5 micron in diameter, however, take 5-1/2

hours to settle 1 foot. Therefore, the smaller particulates travel farther from the burn site before

they settle out of the air (Shigenaka and Barnea 1993).

Particulates 5 to 10 microns in diameter may be inhaled, but most are deposited in the upper

respiratory tract and cleared by mucociliary action, which is efficient and relatively rapid. Only

particulates smaller than 5 microns in diameter reach the sensitive alveolar portion of the lungs.

Clearance of particulates reaching this part of the lungs is much slower and less efficient. The

median size of particulates reaching the alveolar portion of the lungs is 0.5 micron. The mean

size of particulates produced by an in situ burn is also 0.5 micron.

For most populated areas, exposure to particulates only becomes a concern at high

concentrations. Inhaling high doses of particulates can overwhelm the respiratory tract and

cause breathing difficulties (Shigenaka and Barnea 1993). However, for the very old and very

young, and for people with allergies, respiratory problems, and cardiovascular disease, exposure

to particulates can become a concern at much lower concentrations.

Several experiments found high particulate concentrations at ground level only close to the fire.

During the Newfoundland Offshore Burn Experiment, particulates were a concern only up to

150 meters downwind of the fire at sea level; particulate levels dropped to background levels at

1 kilometer downwind of the fire (Fingas et al. 1994a). Particulates in the smoke plume were

800 to 1,000 micrograms per cubic meter near the fire. However, the PM10 concentrations

beneath the plume, even at heights up to 150 to 200 feet above the sea surface and 1 kilometer

downwind, never exceeded background levels (30 to 40 micrograms per cubic meter). Ground-

level concentrations beneath a plume from an Alaska North Slope crude oil test burn on the North

Slope declined from 86 micrograms per cubic meter 0.5 mile downwind to 22 micrograms per

cubic meter 2 miles downwind. Measurements of near-ground smoke concentrations under the

plume from two diesel fires in Mobile, Alabama, peaked at 25 micrograms per cubic meter 6

miles downwind in one case and 15 micrograms per cubic meter 6 miles downwind in the other

(S.L. Ross, 1997 and Fingas et al., 2001)

Polynuclear Aromatic Hydrocarbons. Polynuclear aromatic hydrocarbons (PAHs) are

found in oil and oil smoke. Some PAHs are known or suspected toxins or carcinogens. Long-

term exposure to the higher molecular weight PAHs is generally the basis for human health

concerns.

The PAHs in oil are largely consumed by combustion. During the Newfoundland Offshore Burn

Experiment, PAH concentrations were much less in the plume and in particulate precipitation at

ground level than they were in the starting oil. The mass of all PAHs, including the larger or




multi-ringed PAHs, was reduced by about 6 orders-of-magnitude using combustion (Fingas et al.,

2001).

Westphal et al. (1994) estimated an excess cancer risk of 5 in 100,000 from breathing or ingesting

PAHs in soil after a hypothetical burn of 10,000 gallons of crude oil. This risk is within

U.S. Environmental Protection Agency guidelines for acceptable risk levels. The researchers

found no concern for noncarcinogenic effects from the PAHs. They concluded that adverse

health effects from exposure to PAHs “may not be a significant factor in making a burn/no burn

decision.” Similarly, ASTM (2003), in assessing the results of several experimental burns,

concluded: “In all cases, the quantity of PAHs is less in the soot and residue than in the

originating oil . . . PAHs are not a serious concern in assessing the impact of burning oil.”

Gases. Unlike particulate matter, the gases emitted during a burn do not pose a threat to

human health, because the concentrations in the smoke plume fall below levels of concern at

very short distances downwind of a burn (S.L. Ross 1997, Bronson 1998, and Fingas et al.,

2001).

Volatile organic compounds such as benzene, toluene, n-hexane, and naphthalene can

contribute to acute health effects, such as nausea and headache, at high concentrations. High

concentrations of volatile organic compounds were present within about 50 to 100 meters of

experimental fires (Fingas et al., 2000). However, even higher levels of volatile organic

compounds are emitted from an evaporating slick that is not burning. Therefore, burning actually

results in lower air concentrations of volatile organic compounds than other remedial actions

(Westphal et al. 1994).

Carbon monoxide is a common by-product of incomplete combustion. It is acutely toxic because

it displaces oxygen from the blood and causes oxygen deprivation in the body’s cells. Carbon

monoxide was not detected in the smoke plume from the Newfoundland Offshore Burn

Experiment (Fingas et al. 1994). During the Kuwait oil pool fires, carbon monoxide levels were

much below levels considered to be dangerous (Ferek et al. 1992). Measurements from other

experiments show that at ground level 30 meters downwind of an in situ burn, concentrations are

at or near background levels or are below detection levels (S.L. Ross, 1997 and Fingas et al.,

2001)

Sulfur dioxide is toxic and may severely irritate the eyes and respiratory tract. Sulfur dioxide was

not detected in the smoke plume from the Newfoundland Offshore Burn Experiment (Fingas et al.

1994). Measurements from mesoscale burns ranged from below detection limits to peaks of 1.2

ppm 100 feet downwind, well below the regulatory standards (see Table 6) (S.L. Ross, 1997 and

Fingas et al., 2001).

Nitrogen oxides are strong irritants to the eyes and respiratory tract. The maximum concentration

of nitrogen dioxide found in the plume from the Kuwait oil fires was 0.02 ppm (Ferek et al. 1992),

well below the annual National Ambient Air Quality Standard of 0.053 ppm. Levels of nitrogen

oxides in mesoscale burns were below levels of detectability and thus below levels of concern

(S.L. Ross, 1997 and Fingas et al., 2001).




Environmental Considerations

The potential effects of in situ burning in the marine environment and in inland and upland areas

are not well known or understood, and will vary depending on the specifics of each incident.

Therefore, the potential trade-offs of using in situ burning will be considered on an incident-

specific basis by Federal and State natural resource trustees who have resources affected, or

potentially affected, by an incident. Those resources include, but are not limited to: migratory

birds, marine mammals, terrestrial mammals, finfish, archaeological and historic resources, public

lands, and species and critical habitat designated under the Endangered Species Act. It should

be noted that Federal and State natural resource trustees with responsibility for managing public

lands will also provide to OSCs, available incident-specific information on people who may be

using their lands for subsistence, recreation, mineral exploration, research, or other purposes.

Marine Waters. The following information taken directly from Shigenaka and Barnea (1993)

provides information for Federal and State natural resource trustees when an in situ burn is being

considered in marine water.

Potential ecological impacts of in situ burning have not been extensively discussed or studied.

As a result, the answer to this question is largely speculative and is based on documented

physical effects observed in the laboratory and at limited test burns.

The surface area affected by in-situ burning is likely to be small relative to the total surface area

and depth of a given body of water. This does not necessarily preclude adverse ecological

impacts, particularly if rare or sensitive species use the waters in question. Organisms that may

be affected by in-situ burning include those that use the uppermost layers of the water column,

those that might come into contact with residual materials, and possibly some benthic (bottom-

dwelling) plants and animals.

Direct Temperature Effects. Burning oil on the surface of the water could adversely affect

those organisms at or near the interface between oil and water, although the area affected would

presumable be relatively small.

Role and importance of the surface microlayer. The surface of the water represents a

unique ecological niche called the surface microlayer, which has been the subject of many recent

biological and chemical studies. The microlayer, variously defined but often considered to be the

upper millimeter or less of the water surface, is a habitat for many sensitive life stages of marine

organisms, including eggs and larval stages of fish and crustaceans, and reproductive stages of

other plants and animals. It is known that cod, sole, flounder, hake, anchovy, crab, and lobster

have egg or larval stages that develop in this layer. Although most studies of the microlayer have

been conducted nearshore, some results suggest that even far off the east and west coasts of

North America, eggs and larval stages of fish concentrate at the surface at certain times of the

year. For example, Kendall and Clark (1982) found that densities of Pacific saury larvae more

than 250 miles offshore were equal to, or greater than, densities nearshore.

The surface microlayer frequently contains dense populations of microalgae, with species

compositions distinct from the phytoplankton below the microlayer. Hardy (1986) speculated the

surface layer phytoplankton may play an important biogeochemical role by cycling large amounts

of atmospheric carbon dioxide.




The microlayer also is a substrate for microorganisms and, as such, is often an area of elevated

microbial population levels and metabolic activity. Carlucci and Craven (1986) found microlayer

organisms play an active role in the metabolism and turnover of amino acids.

Potential effects of burning on the surface microlayer.

The ecological importance of the surface microlayer and the potential impacts to it from burning

activities have been discussed in a different but related, context of ocean incineration. The Office

of Technology Assessment (1986) noted in an evaluation of the technique, “given the intermittent

nature of ocean incineration, the relatively small size of the affected area, and the high renewal

rate of the surface microlayer resulting from new growth and replenishment from adjacent areas,

the long-term net loss of biomass would probably be small or non-existent.”

In large-scale burns, temperature increases in the water do not appear to be a problem. During

the Newfoundland Offshore Burn Experiment, the water under the burn showed no increase in

temperature, even though the temperatures at the top of the fire containment boom often reached

1000C (Fingas et al. 1994). The water probably does not heat up because ambient-temperature

seawater is continually supplied below the oil layer as the boom is towed (Shigenaka and Barnea

1993)

Toxicological Considerations. Beyond the direct impacts of high temperature, the by-products of

in-situ burning may be toxicologically significant. Although analysis of water samples collected from

the upper 20 cm of the water column immediately following a burn of crude oil yielded

relatively low concentrations of total petroleum hydrocarbons (1.5 ppm), compounds that have

low water solubility or that associate with floatable particulate material tend to concentrate at the

air-water interface (U.S. EPA, 1986). Strand and Andren (1980) noted that aromatic

hydrocarbons in aerosols originate from combustion associated with human activities, and that

these compounds accumulate in the surface microlayer until absorption and sedimentation remove

them. Higher molecular weight aromatic hydrocarbons, such as those produced by the

combustion of petroleum, have been associated with the incidence of tumors and possibly

reproductive disorders in populations of marine fish. Some of these heavier aromatic

hydrocarbons are known carcinogens in humans and other mammals.

Aquatic toxicity and concentrations of petroleum hydrocarbons in the water in the vicinity of both

burned and unburned crude oil slicks in the open sea is very low. No significant differences were

found in the measurements of toxicity or petroleum hydrocarbons among water samples

associated with unburned oil, burning oil, or post-burn scenarios (Daykin et al. 1994). Burning

does not accelerate the release of oil components or combustion by-products to the water

column (ASTM 2003)

Serious pathologies like tumors have generally been associated with longer-term, or chronic,

exposures to the hydrocarbons. However, exposures attributable to in-situ burning would likely

be short-term and might not result in toxicologically-significant exposures.




Burn Residue. Both residue that floats and residue that sinks may pose some risk of toxicity or

contamination to organisms in the water column (S.L. Ross 1997). Residue that floats may pose

a threat to shorelines and wildlife. The residue may be ingested by fish, birds, and mammals.

The residue also may foul gills, feathers, fur, or baleen (Shigenaka and Barnea 1993). Residue

that sinks may affect benthic animals. In general, however, the effects are less severe than

those from a large, uncontained oil spill, and no specific biological concerns have been identified

to date (ASTM 2003). Oil samples and burn residues collected after the Newfoundland Offshore

Burn Experiment were tested for toxicity to three aquatic species. Neither the residue nor the oil

was toxic, and the burn residue was no more toxic than the oil itself (Blenkinsopp et al. 1997).

Residues of Alaska North Slope crude oil are likely to be sticky semi-solids or non-sticky solids,

depending on the weathering of the oil and the efficiency of the burn. Sticky residues pose a

greater potential environmental risk. They may adhere to birds’ feathers and disrupt the

waterproofing of their plumage or be ingested while the bird is preening (S.L. Ross 1997).

Sunken burn residues can affect benthic resources that would not otherwise be significantly

impacted by a spill at the surface of the water. For example, during the Haven spill in Italy in

1991, approximately 102,000 metric tons of oil burned, and the residues sank. The residue was

distributed over approximately 140 square kilometers of seabed. Local trawl fishermen were

unwilling to fish in the area for two years after the spill because of the expected danger of

contaminating their nets and catch (Martinelli et al. 1995). In 1983, cleanup contractors ignited

the main slick of a spill of Arabian heavy crude from the Honam Jade in South Korea. The fire

burned intensely for about two hours, and the resultant burn residue sank and impacted crabs in

nearby pens (Moller 1992).

Contamination is likely to be local in scale when it occurs at the sea surface or results from

sinking residues that could affect certain unique populations and organisms that use surface

layers of the water column at certain times to spawn or feed. In crafting an effective and

protective response strategy, these effects should be weighed against effects resulting from

alternative actions.

Potential environmental trade-offs. As is the case with all response methods, the

environmental tradeoffs associated with in-situ burning must be considered on a case-by-case

basis and weighed with operational tradeoffs. In-situ burning can offer important advantages

over other response methods in specific cases, and may not be advisable in other, depending on

the overall mix of circumstances.

Pro’s

In-situ burning has the potential for removing large quantities of oil from the surface of the

water with a relatively minimal investment of equipment and manpower.

Burning may offer the only realistic means of removal that will reduce shoreline impacts

in areas where mechanical recovery, containment, and storage facilities may be

overwhelmed by the sheer size of a spill, areas of heavy ice coverage, or in remote or

inaccessible areas where other countermeasures are not practicable.

If properly planned and implemented, in-situ burning may prevent or significantly reduce

the extent of shoreline impacts, including exposure of sensitive natural, recreational, and

commercial resources.




Burning rapidly removes oil from the environment, particularly when compared to

shoreline cleanup activities that may take months or even years.

In-situ burning has the additional attraction of moving products of combustion into the

atmosphere, where they are dispersed relatively quickly.

Con’s

In situ burning, when employed in its simplest form, generates a highly-visible black

smoke plume that may adversely affect human and other exposed populations

downwind.

Burn residues, though normally a small fraction of the oil burned, may sink, making it

harder to recover the residue and to prevent the potential exposure of benthic organisms.

For onshore and inland burns, plant and animal deaths and other adverse biological

impacts may result from the localized temperature elevations at the water body surface.

While these could be expected to occur over a relatively small area, in specific bodies of

water at specific times of the year, affected populations may be large enough or important

enough to represent reasons for not considering burning as a clean-up technique.

The longer-term effects of burn residues on exposed populations of marine organisms

have not been investigated. Additional research is necessary to investigate the long-term

effects.

Inland and/or Upland Areas. The remainder of the information in this section was taken

directly from Zengel, et al 1999 and provides information for Federal and State natural resource

trustees when an in situ burn is being considered in inland and/or upland areas. The information

summarizes the results of a study, where the primary objective was to identify the environmental

conditions under which burning should be considered as a response option for oil spilled in inland

and upland habitats.

Fire ecology and prescribed burning. Applicable information was gathered from the fields of fire

ecology and prescription burning (in the absence of oil). Prescribed fires are often used as a forest

and range management tool, and are often conducted for the same reasons as in situ burning; fire

can be less damaging, more effective, and less costly than chemical and intrusive, mechanical

methods (Wright and Bailey, 1982). There are many lessons already learned by prescribed fire

practitioners and fire ecologists which are directly applicable to the use of in situ burning of spilled oil.

In addition to literature sources, the U.S. Department of Agriculture (USDA) Forest Service maintains

a Fire Effects Information System (FEIS) which was used as the major source for reviewing and

summarizing information on the ecology and effects of fire on specific plant species (Fischer, 1992).

This database can be accessed over the World Wide Web at the following address,

http://www.fs.fed.us/database/feis/welcome.htm. The FEIS contains literature summaries and case

histories from a wide body of sources. Pertinent database fields include the following: fire ecology

and adaptations; post-fire regeneration strategy; immediate fire effect; plant response to fire; fire

management considerations; and fire case studies.



http://www.fs.fed.us/database/feis/welcome.htm


Such summaries should provide spill responders with better information on the potential response of

different habitat types and plant species to in situ burning. Major points from the literature review and

the FEIS ecoregion species summaries on fire effects (in the absence of oil) are discussed below by

major vegetation type.

Trees/forests. Even if they are not killed by fire, trees generally take a long time to recover to pre-fire

levels of structure and dominance relative to smaller, faster growing shrubs and grasses. Fire may

wound or scar trees, providing entry points for pathogens (fungi, insects, etc.) that could lead to

delayed impacts or mortality as a result of fire. In situ burning in most forested areas should be

discouraged; however, for certain types of settings and communities, in situ burning of surface

vegetation within forested areas may be reasonable. Burning might be reasonable for open or

savanna-like forest communities with tree species that are at least moderately fire tolerant, especially

if fire thread to trees is minimal or actively minimized. In situ burning might also be reasonable for a

special fire-prone or fire-adapted forest species or communities under certain conditions, even if trees

will be directly at risk from fire.

Shrubs and Associated Communities. Woody shrubs may be lumped with trees in certain respects,

in that they look similar and may thus be perceived as fire sensitive; however, the shrub species

examined showed a wide range of fire sensitivity, with many species being very fire tolerant. Several

highly fire-tolerant species examined might be good candidates for in situ burning. Shrubs are usually

top-killed by fire, but many sprout vigorously from below-ground parts and recover quickly from fire. It

should be kept in mind that dense shrub thickets can create fire hazards and carry fire to unwanted

areas. Also some very fire-adapted shrub species and communities are also highly- flammable,

presenting additional fire hazards.

Grasses/grasslands. Many graminoids (grasses, sedges, etc.) are fire tolerant and appear to be

good candidates for in situ burning. Most of the species examined respond better during dormant

season burns, and when soil conditions are moist or wet, so that roots, rhizomes, and organic soils

are less likely to be damaged. For native grasslands, natural and prescribed fires are typically low

intensity and fast moving; high intensity, slow burning fires such as those that might be produced by

in situ burning of oil may be more damaging than typical fires. Native grassland species include many

warm-season grasses, dormant in cool season months. Many non-native species which occur in

prairies, pastures, fallow fields, etc., are cool-season grasses, whose growing season may

correspond or overlap with the typical dormant period of warm-season species. The types of grass

species present (warm -season, cool-season, or both) could be an important factor when plant

dormancy and other seasonal concerns are considered in relation to in situ burning. Finally,

although many grasses are fire tolerant, some species or growth forms can be much less so. In

general, bunchgrass species or forms are often more fire sensitive than low-growing, rhizomatous

grasses. Perennial needlegrasses (Stipa spp.) are reported to be the least fire tolerant of the

bunchgrasses, and may not be good candidates for in situ burning.

Conclusions. In situ burning can be a valuable oil spill cleanup tool in inland and upland

environments, particularly under certain conditions. The in situ burning case histories examined,

outline the state of the practice concerning where and when in situ burning is feasible and

environmentally acceptable. In situ burning is clearly suited towards use in certain environmental

settings and habitats, but not others. The case histories also highlight important operational and post-

burn considerations that should be evaluated for each spill.

Given the available case-history information, the overall knowledge and information base concerning

in situ burning of inland and upland environments is still limited. To help add to this knowledge base,




summary information from the fields of fire ecology and prescribed burning (in the absence of oil) is a

valuable tool, increasing the information available to oil spill responders concerning the potential

responses of different habitat types and plant species to in situ burning. The use of information

gathered from the fire ecology and effects literature comes with a strong disclaimer, however. Fire-

sensitive vegetation types where in situ burning should definitely not be used can be clearly identified,

however, the appropriateness of burning of oil in plant communities described as fire tolerant or

resistant is largely untested. Due to the complexity of fire science and prescribed burning, and fire

ecology and environmental effects in particular, we suggest that prescribed-fire practitioners be

consulted when in situ burning is planned, to provide valuable knowledge and experience not likely

possessed by spill responders.









5. References

5. REFERENCES

Alaska Regional Response Team. 1994. In Situ Burning Guidelines for Alaska. Appendix II,

Annex F, in The Alaska Federal/State Preparedness Plan for Response to Oil and Hazardous

Substance Discharges/Releases.

Allen, A. 1990. Contained controlled burning of spilled oil during the Exxon Valdez oil spill. In

Proceedings of the Thirteenth Arctic and Marine Oilspill Program (AMOP) Technical Seminar.

June 6-8, Edmonton, Alberta, pp. 305-313.

Alyeska Pipeline Service Company. 1996. Supplemental Information Document #16: Burning as

a Response Tool. In Prince William Sound Tanker Oil Discharge Prevention and Contingency Plan,

Supplemental Information Documents, Edition 1, Revision 1, dated December 31, 1996, Alyeska

documents no. PWS-203-16. Anchorage. 92 pp.

American Society for Testing and Materials (ASTM). 2003. Standard guide for in situ burning of

oil spills on water: Environmental and operational considerations. Designation: F 1788-2003.

American Society for Testing and Materials (ASTM). 2007. In Situ Burning of Spilled Oil: Fire-

Resistant Boom Designation: F2152 (2007).

Blenkinsopp, S., G. Sergy, K. Li, M. Fingas, K. Doe, and G. Wohlgeschaffen. 1997. Evaluation

of the toxicity of the weathered crude oil used at the Newfoundland Offshore Burn Experiment

(NOBE) and the resultant burn residue. In Proceedings of the Twentieth Arctic and Marine

Oilspill Program (AMOP) Technical Seminar. June 11-13. Vancouver, British Columbia. pp. 677-

684.

Bronson, M. 1998. In situ burning safe distance predictions with ALOFT-FT model. Prepared by

EMCON Alaska, Inc., for Alaska Department of Environmental Conservation.

Buist, I., J. McCourt, and J. Morrison. 1997. Enhancing the in situ burning of five Alaskan oils

and emulsions. 1997. In Proceedings of the 1997 International Oil Spill Conference. April 7-10.

Fort Lauderdale, Florida. pp. 121-129.

Buist, I., J. McCourt, K. Karunakaran, C. Gierer, D. Comins, N. Glover, and B. McKenzie. 1996.

In situ burning of Alaskan oils and emulsions: Preliminary results of laboratory tests with and

without waves. In Proceedings of the Nineteenth Arctic and Marine Oilspill Program (AMOP)

Technical Seminar, June 12-14, Calgary, Alberta, pp. 1033-1061.

Buist, I., K. Trudel, J. Morrison, and D. Aurand. 1995a. Laboratory studies of the physical

properties of in situ burn residues. In Proceedings of the Eighteenth Arctic and Marine Oilspill

Program (AMOP) Technical Seminar, June 14-16, Edmonton, Alberta, pp. 1027-1051.



5. References

Buist, I., N. Glover, B. McKenzie, and R. Ranger. 1995b. In situ burning of Alaska North Slope

emulsions. In Proceedings of the 1995 International Oil Spill Conference. February 27-March 2.

Long Beach, California. pp. 139-146.

Buist, I. 1989. Disposal of spilled Hibernia crude oils and emulsions: In situ burning and the

“Swirlfire” burner. In Proceedings of the Twelfth Arctic and Marine Oilspill Program (AMOP)

Technical Seminar. June 7-9, Calgary, Alberta, pp. 245-277.

Buist, I., and D. Dickins. 1987. Experimental spills of crude oil in pack ice. In Proceedings of the

1987 International Oil Spill Conference, pp. 373-380.

Campbell, T., E. Taylor, and D. Aurand. 1994. Ecological risks associated with burning as a spill

countermeasure in a marine environment. In Proceedings of the Seventeenth Arctic and Marine

Oil Spill Program (AMOP) Technical Seminar, June 8-10, Vancouver, British Columbia, pp. 707-

716.

Daykin, M., G. Sergy, D. Aurand, G. Shigenaka, Z. Wang, and A. Tang. 1994. Aquatic toxicity

resulting from in situ burning of oil-on-water. In Proceedings of the Seventeenth Arctic and

Marine Oil Spill Program (AMOP) Technical Seminar. June 8-10. Vancouver, British Columbia.

pp. 1165-1193.

Evans, D., W. Walton, H. Baum, R. Lawson, R. Rehm, R. Harris, A. Ghoniem, and J. Holland.

1990. Measurement of large scale oil spill burns. In Proceedings of the Thirteenth Arctic and

Marine Oil Spill Program Technical Seminar, June 6-8, 1990, Edmonton, Alberta, pp. 1-38.

Ferek, R., P. Hobbs, J. Herring, K. Laursen, R. Weiss, and R. Rasmussen. 1992. Chemical

composition of emissions from the Kuwait oil fires. Journal of Geophysical Research 97: 14483-

14489.

Fingas, M., G. Halley, F. Ackerman, N. Vanderkooy, R. Nelson, M. Bissonnette, N. Laroche,

P. Lambert, P. Jokuty, K. Li, W. Halley, G. Warbanski, P. Campagna, R. Turpin, M. Trespalacios,

D. Dickins, E. Tennyson, D. Aurand, and R. Hiltabrand. 1994. The Newfoundland Offshore Burn

Experiment: NOBE experimental design and overview. In Proceedings of the Seventeenth Arctic

and Marine Oil Spill Program (AMOP) Technical Seminar. June 8-10. Vancouver, British

Columbia. pp. 1053-1063.

Fingas, M.F. and M. Punt, 2000. “In-Situ Burning: A Cleanup Technique for Oil Spills on Water”,

Environment Canada Special Publication, Ottawa, Ontario, 214 p.

Fingas, M.F., P. Lambert, Z. Wang, K. Li, F. Ackerman, M. Goldthorp, R. Turpin, P. Campagna,

R. Nadeau, and R. Hiltabrand, “Studies of Emissions from Oil Fires”, in Proceedings of the

Twenty-fourth Arctic and Marine Oil Spill Program Technical Seminar, Environment Canada,

Ottawa, Ontario, pp. 767-823, 2001.

Fingas, M.F., Z. Wang, B. Fieldhouse, C.E. Brown, C. Yang, M. Landriault and D. Cooper, 2005,

“In-situ Burning of Heavy Oils and Orimulsion: Analysis of Soot and Residue”, in Proceedings of

the Twenty-eighth Arctic and Marine Oil Spill Program Technical Seminar, Environment Canada,

Ottawa, Ontario, pp. 333-348.



5. References

Fischer, W.C., 1992. The Fire Effects Information System Database. U.S. Department of

Agriculture, Forest Service, Intermountain Research Station, Intermountain Fire Sciences

Laboratory, Missoula, Montana.

Guenette, C., and P. Sveum. 1995. In situ burning of uncontained crude oil and emulsions. In

Proceedings of the Eighteenth Arctic and Marine Oilspill Program (AMOP) Technical Seminar,

June 14-16, Edmonton, Alberta, pp. 997-1010.

Hardy, J.T. 1986. Workshop on the sea-surface microlayer in relation to ocean disposal—

phytoneuston: plants of the sea-surface microlayer. In U.S. EPA, Proceedings of the workshop

on the sea-surface microlayer in relation to ocean disposal, December 18-19, 1985, Airlie,

Virginia, pp. C39-C41.

Industry Task Group. 1984. Oil Spill Response in the Arctic, Part 3, Technical Documentation.

Shell Western E&P, Inc.; Sohio Alaska Petroleum Company; Exxon Company, U.S.A.; and Amoco

Production Company. Anchorage, Alaska. 76 pp.

Kendall, A.W. and J. Clark. 1982. Icthyoplankton off Washington, Oregon, and northern California,

April-May 1980. NWAFC Processed Report 82-11. Seattle: Northwest and Alaska Fisheries

Center, National marine Fisheries Service, National Oceanic and Atmospheric Administration.

Martinelli, M., A. Luise, E. Tromellini, T. Sauer, J. Neff, G. Douglas. 1995. The M/C Haven oil

spill: Environmental assessment of exposure pathways and resource injury. In Proceedings of

the 1995 International Oil Spill Conference. February 27-March 2, Long Beach, California, pp.

679-685.

McGrattan, K., H. Baum, W. Walton, and J. Trelles. 1997. Smoke plume trajectory from in situ

burning of crude oil in Alaska: Field experiments and modeling of complex terrain. U.S.

Department of Commerce, National Institute of Standards and Technology. January. 127 pages.

Moller, T.H. 1992. Recent experience of oil sinking. In Proceedings of the Fifteenth Arctic and

Marine Oilspill Program (AMOP) Technical Seminar. June 10-12, Edmonton, Alberta, pp. 11-14.

National Oceanic and Atmospheric Administration (NOAA), Hazardous Materials Response and

Assessment Division. 2005. ADIOS (Automated Data Inquiry for Oil Spills) User’s Manual.

Prepared for The U.S. Coast Guard Research and Development Center, Avery Point, Groton,

Connecticut. April.

National Response Team Science & Technology Committee. 1997a. Guidance for developing a

site safety plan for marine in situ burn operations. November.

National Response Team Science & Technology Committee. 1997b. Fact sheet: Site safety

plans for marine in situ burning operations. November.

National Response Team Science & Technology Committee. 1995. Guidance on burning spilled

oil in situ. December.

Office of Technology Assessment. 1986. Ocean Incineration: Its Role in Managing Hazardous

Waste. Washington, DC: U.S. Government Printing Office, 223 pages.



5. References

Shigenaka, G., and N. Barnea. 1993. Questions about in situ burning as an open-water oil spill

response technique. National Oceanic and Atmospheric Administration. HAZMAT Report 93-3.

June. 42 pages.

S.L. Ross Environmental Research Ltd. 1997. A review of in situ burning as a response for spills

of Alaska North Slope crude oil in Prince William Sound. Prepared for Prince William Sound

Regional Citizens Advisory Council. May 20.

Strand, J.W., and A.W. Andren. 1980. Polyaromatic hydrocarbons in aerosols over Lake

Michigan, fluxes to the lake. In Polynuclear Aromatic Hydrocarbons: Chemistry and Biological

Effects. Columbus: Battelle Press. Pp. 127-137.

Trudel, B.K., I.A. Buist, D. Schatzke, and D. Aurand. 1996. Laboratory studies of the properties

of in situ burn residues: Chemical composition of residues. In Proceedings of the Nineteenth

Arctic and Marine Oilspill Program (AMOP) Technical Seminar, June 12-14, Calgary, Alberta, pp.

1063-1079.

U.S. Environmental Protection Agency. 2006. National Ambient Air Quality Standards for

Particulate Matter; Final Rule, 40 CFR Part 50, October 17, 2006.

U.S. Environmental Protection Agency. 1991. In situ burning workshop, May 21-22, 1991,

Sacramento, California. 7 pp. + appendices.

U.S. EPA. 1986. Proceedings of the workshop on the sea-surface microlayer in relation to

ocean disposal, December 18-19, 1985, Airlie, Virginia. Washington, D.C.: Office of Marine and

Estuarine Protection, U.S. Environmental Protection Agency. 26 pp + appendices.

Westphal, P., E. Taylor, and D. Aurand. 1994. Human health risk associated with burning as a

spill countermeasure. In Proceedings of the Seventeenth Arctic and Marine Oil Spill Program

(AMOP) Technical Seminar, June 8-10, Vancouver, British Columbia, pp. 685-705.

Wright, H.A. and A.W. Bailey, 1982. Fire Ecology, United States and Southern California. John

Wiley and Sons, Inc., New York, NY. 501 pp.

Zengel, S.A., J.A. Dahlin, C. Headley, and J. Michel. 1999. Environmental Effects of In Situ

Burning in Inland and Upland Environments. Proceedings of the 1999 International Oil Spill

Conference. American Petroleum Institute. Washington, DC, 5 pp. Available on CD-ROM from

API.



Appendix 1: Application and Burn Plan


Incident Name:

Incident Location:

Incident Date:

Incident Time:

Date Prepared Operational Period

Date Time

Time Prepared

Start:

End:

Title of Applicant: Address:

Affiliation: Phone: Fax:

PART 1 Release Status (check one):

Continuous Potential Burn Location

Intermittent Site Description

One time only, now stopped Latitude

Longitude If Continuous or Intermittent, estimated Rate of Release:

gallons, or Type of Incident (check one):

BBL Grounding

Transfer Operations Estimated Surface Area Covered (square miles)

Explosion At Time of Application

Collision If inland, identify/describe:.

Blowout Vegetative cover at burn site (e.g., wetlands, grasslands, shrublands, forest, tundra, non-vegetated)

Other Fire danger rating at and near the burn site (see Appendix 6) Whether burn is on permafrost

Any ignitable vegetation near the burn Product Released (check one): Any structures/buildings near the burn

North Slope Crude Why is mechanical recovery alone inadequate for spill response?

Cook Inlet Crude

Residual/Bunker Oil Consider the spill size, forecasted weather and trajectories,

Diesel #2 amount of available equipment, time to deploy, and time to

JP4 recover.

Other

Will you use mechanical recovery in conjunction with

Estimated Volume of Released Product: in situ burning? yes no

gallons, or

BBL Have you evaluated dispersants? yes no

Estimated Volume of Product That May Potentially be Released: Will you use dispersants in conjunction with

gallons, or in situ burning? yes no

BBL Why is in situ burning preferred?



PART 2

Appendix 1: APPLICATION AND BURN PLAN In Situ Burning Guidelines for Alaska

Tidal state at o’clock (check one):

Did source burn? yes no

Is source still burning? yes no

Is product easily emulsified? yes no

Is product already emulsified? (check one)

No

Light emulsion (0-20%)

Moderate emulsion (21-50%)

Heavy emulsion (>50%)

Unknown

Estimated Percent Oil Naturally Dispersed and Evaporated Within

First 24 Hours:

Check boxes and enter wind values in the following table:

Slack tide

Incoming (flood)

Outgoing (ebb)

./ Attach a graph with tidal information for three tidal cycles.

Dominant current (not drift):

Speed (knots)

Direction (to)

Current Speed (knots) Relative to the Containment

Boom

Note: Current speed relative to the fire boom should be .75 knots

or less to minimize entrainment.

Sea State (check one):

Calm

Choppy

Swell

Waves (estimate height in feet)

Does your site safety plan cover this in situ burn plan?

yes no

Will response workers be briefed on the site safety plan

before burning? yes no

Percentage Ice Coverage (check one):

No ice present

<10%

11-30%

31-50%

51-100%

Are the responders trained and equipped with safety gear?

yes no

./ Attach an ICS 204 form, or similar document. On it, list

the following equipment you will use:

Vessels

Aircraft for ignition and aerial observation

Lengths of fire boom

Residue containment and removal equipment

Fire fighting equipment

Ignition systems

Burn promoters

Communications systems

Air/plume monitoring equipment.

Current

Conditions 12-hour

Forecast

24-hour

Forecast

Clear

Partly cloudy

Overcast

Rain

Snow

Fog

Wind Speed

(kt)

Wind Direction

(from)



Appendix 1: APPLICATION AND BURN PLAN In Situ Burning Guidelines for Alaska

Part 3

./ Attach a chart with a distance scale. Show estimated spill

trajectory and landfalls, with time. Show the location and distance of your proposed burns relative to the following features:

1. Source:

Location

Distance from Burn (miles)

2. Ignitable slicks:

Location


3. Nearest Land (burns on water) or Non-Flat Terrain (burns on land):

Location

Distance from burn (miles)

Nearby Populated Areas (i.e., one or more non-spill-related people

present):

Location


Location


Location


For Inland Burns consider Ignitable vegetation

Structures/buildings

Areas with Fire Danger Rating of extreme, very high, or high

Nearest airport

Alaska Class I Area (see Appendix 4)

4. Attach a drawing showing your mechanical recovery and in situ

burning equipment configurations.

6. For burns potentially impacting populated areas, provide an air

monitoring plan in accordance with the SMART protocols.

7. Identify whether any Class 1 Areas (Appendix 4) will be

impacted.

Proposed Burn Date and Time

Describe how you intend to carry out the burn.

Check one:

Ignition is away from source after containment and movement of the oil to safe location (i.e., controlled burn).

Ignition of uncontained slick(s) is at a safe distance from the source.

Ignition is at or near source without controls.

How will you ignite the oil?

Enter the volume of oil you expect to burn:

How many simultaneous burns are planned?

What distance will separate simultaneous burns?

Are you planning sequential or repeat (not simultaneous) burns? yes no

Estimated area of oil in uncontrolled burn

(square feet)

Describe your ability and procedures to extinguish the burn if

necessary or directed to do so.

Fire No.

Oil Volume (BBL or Gal )

Fire Duration (Hrs or Min )

1

2

3

4

5

Attach a list for more fires.

Total Vol.:



Part 4

How do you plan to collect burned oil residue?

How do you plan to store and dispose of burned oil residue?

For inland burns, how do you plan to address post- burn erosion if applicable?

Describe plan for eliminating risk (if any) of accidental (secondary) fires (e.g., structures/buildings and/or vegetation).

Will the burn affect visibility at downwind airports within 20 miles?

Signatures

Signature of Applicant

Printed name of Applicant

Date and Time Submitted to Federal and State On-Scene Coordinators

Prepared by: ICS Position: Phone:

Appendix 1: APPLICATION AND BURN PLAN




Appendix 2: FOSC/SOSC Review Checklist In Situ Burning Guidelines for Alaska

Note: If an in situ burn is being considered, immediately notify the EPA ARRT representative (unless EPA is the FOSC), the DOI and DOC ARRT representatives, and the USCG Strike Team to provide advance notice of this possibility.

STEP 1: Review of the completed Application to Burn Plan

Is burning an appropriate response option, when considering mechanical yes no containment and recovery and/or dispersant use?

STEP 2: Determine feasibility of burning

Will the oil become 2 to 3 mm thick? yes no

Is the oil relatively fresh (less than 2 or 3 days of exposure)? yes no

Does the oil contain less than 25 percent water? yes no

Is visibility sufficient to see oil and vessels towing boom, and suitable for aerial yes no

overflight for burn observation?

If burning may involve darkness or poor visibility, can the burn be completed yes no safely and well away from any populated areas or other sensitive resources?

Is wind less than 20 knots? yes no

Are currents less than 0.75 knots relative to the boom? yes no

Are waves less than 3 feet in choppy, wind-driven seas or less than 5 to 6 feet

in large swells? yes no

Does the responsible party have a site safety plan for this incident that specifically

addresses the proposed burning operations? yes no

Will response workers be briefed on this plan before burning starts? yes no

Are personnel trained and equipped with safety gear? yes no

Is a communications system available and working to communicate with

and between aircraft, vessels, and control base? yes no

Are operational and environmental conditions feasible for burning? yes no

Can the fire be extinguished and are the procedures for addressing this contingency adequate? yes no

Will the burn meet the operational criteria for:

the next 24 hours? yes no the next 48 hours? yes no

STEP 3: Determine whether burn may be conducted at a safe distance from populated areas.

Burning Near Unpopulated Areas:

To help determine whether an area that could be affected by an in situ burn smoke plume is unpopulated, the Unified Command will consult with land managers and (to the extent practical) land owners of the area to help determine whether there may be individuals using the area for activities including, but not limited to, fishing, hunting, berry picking, boating, backpacking, or conducting research. The Unified Command may require further verification by aerial reconnaissance or some similar means.

Will the smoke plume pass into populated areas? yes no

If no, proceed to Step 4. If yes, consider the following conditions of authorization.



APPENDIX 2: FOSC/SOSC REVIEW CHECKLIST


Burning in Flat Terrain Near Populated Areas:

Is the burn in an area near or adjacent to populated areas? yes no

Are local government, land managers, land owners, and/or state emergency service personnel involved in

planning for, and if necessary assisting with, public notifications? yes no

On water more than 3 miles from shore, the Green Zone safe distance is 1 mile from populated areas. On

land or on water less than 3 miles from shore, the green zone safe distance is 3 miles from populated

areas. Burning at a green zone safe distance from populated areas is acceptable. Proceed to Step 4.

The Yellow Zone distance is from 1 to 3 miles downwind of a burn, and within 45 degrees of the smoke

plume, when the burn is on land or on water within 3 miles of shore. If the potentially-impacted population

can be sheltered in place or evacuated during the burn, proceed to Step 4. If potentially-impacted populated

areas cannot be protected, do not authorize burning at this time.

The Red Zone distance is within 1 mile of any burn. Burns within 1 mile of populated areas may be

authorized if the potentially-impacted population can be sheltered in place or evacuated during the burn,

and if best professional judgment supports the expectation of PM2.5 less than 65 micrograms per cubic

meter 1-hour average in populated areas. If these conditions can be met, proceed to Step 4. If these

conditions cannot be met, do not authorize burning at this time.

Burning when the Safe Distance Is Not Predicted:

The Unified Command determines whether flat terrain exists through the use of topographic maps and on- scene weather information, and input, as appropriate, from the National Weather Service and the Alaska Interagency Coordination Center.

According to best professional judgment, will PM2.5 concentrations remain below 65 micrograms per cubic

meter 1-hour average in populated areas? yes no

If yes, proceed to Step 4. If no, do not authorize burning at this time.

Notifications and Warnings:

Is it possible to implement Level 1 general notification in the Green Zone? yes no

Is it possible to implement a Level 2 alert notification in the Yellow Zone? yes no

Is it possible to implement a Level 3 warning notification, which includes

in-place sheltering?

Is it possible to implement a Level 4 emergency notification, which includes temporary evacuation? yes no



STEP 4: Determine whether environmental and other considerations will be adequately

addressed.

Have potentially-affected natural resources and historic properties been identified and adequately addressed? yes no

If no, document rationale in decision memo.

Have potentially-affected other considerations (e.g., structures/buildings)

been identified and adequately addressed? yes no

If no, document rationale in decision memo.

STEP 5: Review of consultations and requests for authorization.

NCP Authorization of Use

Concurrence Required:

Y EPA (FOSC or EPA ARRT representative) yes no conditional Y State (SOSC in Unified Command) yes no conditional

Consultation as per the NCP (If other than yes, document how addressed) Y DOI ARRT Representative yes no conditional Y DOC ARRT Representative yes no conditional

Other Consultations with Representatives of Potentially Affected Stakeholders:

Other State and/or Federal natural resource trustees yes no conditional

Federally-recognized tribes yes no conditional

Federal, State, and/or local safety and public health agencies yes no conditional

Land Owners: Y Local (e.g. borough, municipal governments yes no conditional Y Private Land owners (e.g. Native corporations) yes no conditional

Others (e.g., Regional Citizens Advisory Councils, Port Authorities, yes no conditional Area safety/security committees, law enforcement, etc.)

For a burn that may affect threatened and/or endangered yes no conditional species and/or their critical habitat, DOI-Fish and Wildlife Service* and/or National Marine Fisheries Service ESA Specialists*

For a burn that may affect historic properties, the FOSC’s yes no conditional Historic Properties Specialist.

For a burn proposed in conjunction with an Outer Continental Shelf Facility,

the DOI-MMS Regional Supervisor for Field Operations* yes no conditional





STEP 6. Make decision on whether to authorize burn.

Authorization and Conditions:

The on-scene coordinators’ decision based on review (check one):

Do not conduct in situ burning.

In situ burning may be conducted in limited or selected areas (see attached chart).

In situ burning may be conducted over the limited period of day(s).

In situ burning may be conducted as requested in the application.

Other, as specified:

Conditions:

1. The burn operations team will visually monitor the smoke plume in accordance with the monitoring

plan.

2. The burn operations team will collect the burn residue in accordance with the burn plan.

3. Public notification/warning to people in populated areas who may be in proximity to any of the three

safe distance zones in accordance with the notification.

4. Other incident-specific conditions of authorization (e.g., air monitoring in accordance with the

SMART protocols) for a burn with the potential to impact populated areas:

Signature of Federal On-Scene Printed Name of Federal On-Scene Date and Time Coordinator Coordinator

Signature of State On-Scene Printed Name of State On-Scene Date and Time Coordinator Coordinator

Prepared By: ICS Position: Phone:



Yellow Zone

45o

45o

mile

Figure 5. In Situ Burn Zones

5A: Zones for in situ burns on populated flat terrain, or on water within 3 miles of shore.

5B: Zones for in situ burns on water more than 3 miles from shore.

Green Zone

1 mile

3 miles

Red Zone

Green Zone

1

Red Zone








APPENDIX 3: SAMPLE UNIFIED COMMAND DECISION DOCUMENT FOR IN SITU BURNING

Unified Command Decision Document

Authorization to proceed with in situ burning is approved with the following conditions:

1) This approval is for (date). Continued in situ burn operations shall be subject to daily review and approval by the Unified Command. This authorization may be terminated by the Unified Command at any time.

2) The in situ burn operation shall not inhibit or impact on going recovery operations approved by the Unified Command

3) The RP or applicant shall implement a plan to collect residual or unburned oil following the completion of the in situ burn.

4) The applicant shall implement the approved in situ burning site safety plan to provide for the safety of personnel.

5) The Unified Command shall maintain public notification and warning procedures for the duration of the in situ burning operation.

6) The Unified Command shall perform visual monitoring (and air monitoring, where necessary) to ensure the operation and smoke plume is conducted as projected and will not impact either populated areas or the mechanical operations. The applicant shall ensure that the monitoring team includes representatives as determined by the Unified Command to monitor the burn.

7) In situ burn efficacy observations and visual monitoring reports should include the amount of oil burned, the location of the burn, the time and duration of burn, the boom condition, wind direction and plume characteristics. These reports shall be submitted to the Unified Command on a daily basis, no later than 12:00 noon the day following the burn, for consideration in approval for continued burning operations.

8) Following the burn operation, a detailed after-action report will be submitted by the RP denoting the actions taken and the lessons learned from the operation.

FOSC: Date:

SOSC: Date:

LOSC (if required): Date:

Incident Commander: Date:



(This page intentionally blank)



Appendix 4: Class I Areas in Alaska

* This figure shows areas in Alaska, which are identified in accordance with the Clean Air Act and subsequent amendments, as “Class I Areas.” They include one national park and preserve managed by the U.S. Department of the Interior-National Park Service (DOI-NPS) and three national wilderness areas managed by the DOI-Fish and Wildlife Service (DOI-FWS). Class I Areas receive a higher standard of air quality control to protect the visual quality of these scenic areas. In doing so, a higher level of environmental protection from air pollutants is also achieved.




Appendix 5: Air Quality Monitoring Equipment in Alaska

Monitor Location

Monitor Measurement Capability

Stationary or Portable

Continuous or Manual

Agency Owner

Agency Contact Phone Number

Fairbanks PM-10, PM-2.5 S C/M Alaska Department of Environmental Conservation

907-269-6249 Anchorage PM-10, PM-2.5 S C/M

Juneau PM-10, PM-2.5 S C/M

Butte PM-10, PM-2.5 S C/M

*Wasilla PM-10, PM-2.5 S C/M

*Palmer PM-10, PM-2.5 S C/M

*Soldotna PM-10, PM-2.5 S C/M

Anchorage PM-2.5 (2 EBAMs) P C

Anchorage PM-2.5 (2 EBAMs) P C Department of the Interior- Fish and Wildlife Service

907-271-5011

Tuxedni Bay PM-10, aerosols (IMPROVE) S M

Sand Point PM-10, aerosols (IMPROVE) S M

Denali National Park

PM-10, aerosols (IMPROVE) S M Department of the Interior-National

Park Service

907-271-5011

Trapper Creek PM-10, aerosols (IMPROVE) S M

*Bettles PM-10, aerosols (IMPROVE) S M

Fairbanks PM-2.5 (2 EBAMs) P C/M Department of the Interior-Bureau

of Land Management

907-271-5011

Petersburg PM-10, aerosols S U.S. Forest Service 907-772-5865

Anchorage PM-2.5 (2 DataRAMs) P M Environmental Protection Agency 907-257-1342

Anchorage PM-.1-10 (2 PDR 1000s) P M

Anchorage VOC, O2, CO2, LEL (3 Area RAEs)

P C/M

*These sites are due online in 2008.

Note: “Continuous” monitors run 24 hours a day, 7 days a week and an operator does not have to be present for the sampler to run.






Appendix 6: Fire Danger Rating for Inland Areas

Fires start quickly, spread furiously, and burn intensely. All fires are potentially serious. Development into high intensity burning will usually be faster and occur from smaller fires than in the very high fire danger class. Direct attack is rarely possible and may be dangerous except immediately after ignition. Fires that develop headway in heavy slash or in conifer strands may be unmanageable while the extreme burning condition lasts. Under these conditions the only effective and safe control action is on the flanks until the weather changes or the fuel supply lessens.

Fires start easily from all causes and, immediately after ignition, spread rapidly and increase quickly in intensity. Spot fires are a constant danger. Fires burning in light fuels may quickly develop high intensity characteristics such as long-distance spotting and fire whirlwinds when they burn into heavier fuels.

All fine dead fuels ignite readily and fires start easily from most causes. Unattended brush and campfires are likely to escape. Fires spread rapidly and short-distance spotting is common. High-intensity burning may develop on slopes or in concentrations of fine fuels. Fires may become serious and their control difficult unless they are attacked successfully while small.

Fires can start from most accidental causes, but with the exception of lightning fires in some areas, the number of starts is generally low. Fires in open cured grasslands will burn briskly and spread rapidly on windy days. Timber fires spread slowly to moderately fast. The average fire is of moderate intensity although heavy concentrations of fuel, especially draped fuel, may burn hot. Short-distance spotting may occur, but is not persistent. Fires are not likely to become serious and control is relatively easy.

Fuels do not ignite readily from small firebrands although a more intense heat source, such as lightning, may start fires in duff or punky wood. Fires in open cured grasslands may burn freely a few hours after rain, but woods fires spread slowly by creeping or smoldering, and burn in irregular fingers. There is little danger of spotting.

Source: U.S. Forest Service – Wildland Fire Assessment System




